Kyc Onboarding Assessment

Corporate KYC Onboarding Assessment

Domain method for deciding whether a prospective corporate customer can be onboarded, under BSA, FATF, and OFAC obligations. This skill describes how to reason about the evidence; the KYC data tools (exposed through the gateway) supply the evidence itself.

When to use

Corporate onboarding, a periodic KYC refresh, or whenever a sanctions or adverse-media alert fires against an existing customer.

Evidence to gather (via the KYC tools)

Pull all of these before forming a view — a decision on partial evidence is itself a finding to escalate, not an approval:

• get_customer_profile — legal entity, directors, beneficial owners, standing risk flags, KYC status.
• credit_bureau_report — rating, facilities, payment history, leverage and liquidity ratios.
• sanctions_screen — OFAC / UN / EU / UK HMT sanctions and PEP screening, AML risk rating, whether enhanced due diligence (EDD) is required.
• transaction_history — counterparties, geographic distribution, high-risk jurisdictions, suspicious patterns.
• adverse_media_scan — negative news on the entity and its principals.

Method

1. Sanctions exposure. Any match — including a partial match — is material and must be called out. It blocks a clean compliance status.
2. PEP exposure. A flagged director or beneficial owner makes EDD mandatory before onboarding.
3. Beneficial-ownership transparency. Can the ultimate owners be identified? Opacity is a risk factor, not a neutral fact.
4. Geographic risk. Weight exposure to high-risk or sanctioned jurisdictions.
5. Transaction patterns. Flag structuring (repeated transactions just under a reporting threshold, e.g. amounts at $99,999), round-amount activity, and unexplained volume.
6. Adverse media. Regulatory actions, investigations, and reputational findings relevant to the banking relationship.
7. Credit standing. Rating, repayment capacity, leverage, and payment discipline — a thin or deteriorating credit profile raises the score but does not, by itself, block onboarding.

Decision rules

• A sanctions match (including partial) means the customer cannot be approved without resolution — escalate or reject.
• A flagged PEP triggers mandatory EDD; do not approve until it is complete.
• A structuring pattern must be escalated as potentially SAR-reportable.
• Compliance failures dominate credit ones: a customer with strong credit but an unresolved sanctions/PEP/structuring finding is REJECT or ESCALATE, never APPROVE.
• If the assessment cannot be completed, return ESCALATE — never a silent APPROVE.

Output

Return a single decision with its rationale:

• decision — APPROVE | REJECT | ESCALATE
• risk_score — 0-100 (higher is riskier)
• key_factors — the specific findings driving the decision, naming the databases, jurisdictions, and patterns relied on
• obligations — any triggered filing or EDD requirement (e.g. SAR, EDD)

Cite specifics

Name what you relied on: the sanctions databases screened, the jurisdictions involved, the transaction pattern observed, and the regulatory obligation triggered (for example, 31 USC 5324 for structuring, or FATF Recommendation 12 for PEPs). A vague verdict is not auditable.