Perpetual KYC is the idea that a customer file should update when something changes rather than on a calendar. It is a better model than the periodic sweep and it is sold to firms that are in no position to adopt it, because it assumes a book whose files are complete and current. Most firms that ask about it have a back book that is neither, and the honest first project is remediation.
What continuous review actually requires
Three things, and the third is the one that gets skipped. A complete file per customer, so there is something to update. A trigger, meaning some signal that a fact has changed. And an owner for each file who receives the trigger and acts on it. Without the third, continuous KYC produces a stream of events nobody works, which is worse than a periodic review because it feels like coverage. The model is sound; it just cannot be bought as a feature.
Remediation is the unglamorous prerequisite
Remediation means going back through customers taken on before your current standard and bringing their files up to it. It is dull, it is expensive, and it is the only route from where most firms are to where they want to be. The scale is worth measuring before it is planned: how many customers have no recorded review date, how long a review takes at each rating, and therefore how many hours the backlog represents. The free checklist on this site produces exactly those three numbers.
Do it in rating order, not in date order
The instinct is to work oldest first. The better order is highest risk first, because the exposure is concentrated there and because the enhanced files are the ones most likely to have changed. Working in rating order also gives you a defensible story if you are asked mid-project: you can say which part of the book has been brought current and why that part was chosen, which is a far better answer than working through an alphabet.
Questions people ask about perpetual kyc
Is perpetual KYC a product or an approach?
An approach. Products can supply triggers and hold the file, but the thing that makes it work is an owner per customer who acts when a trigger arrives, and that is an operating decision.
How do we size a remediation?
Count the files with no recorded review date, multiply by the review time at each rating, and price it at the cost of the hour. That is what the free checklist does, and the resulting number is usually the reason remediation gets scheduled.
Can we go continuous for some customers and periodic for others?
Yes, and most firms end up there. Continuous for the higher-risk book where triggers matter, periodic for the standard book. What matters is that every file has a stated model and a next date, rather than some files having neither.