Continuous KYC (perpetual KYC)
Also known as: Perpetual KYC · pKYC · Ongoing due diligence · Ongoing customer monitoring
Keeping customer knowledge current across the whole relationship, re-assessing risk whenever something changes, instead of verifying once at onboarding and never again.
Legal basis
31 CFR 1020.210 (AML program; customer due diligence, ongoing monitoring)
Traditional KYC is an event: verify at onboarding and file it away. But risk does not stop at account opening — the customer becomes a PEP, appears on a list, changes behavior, is caught up in an investigation. Continuous KYC (or *perpetual KYC*) replaces the manual periodic review with event-driven re-assessment. It maps directly onto FinCEN's customer due diligence rule, which requires ongoing monitoring to keep customer information current and to identify and report suspicious activity — not a one-time check.
In practice, it is what turns watchlist screening and transaction monitoring into a living process: on every list update or material change, the customer is rescored, and only the cases that actually changed rise for review. It avoids both the cost of re-verifying everyone every year and the gap of trusting forever a check made on day one.
Frequently asked questions
What is perpetual KYC?
It is keeping KYC continuously up to date across the relationship, re-assessing the customer's risk when an event changes their profile (they appear on a list, become a PEP, change behavior), rather than verifying only at onboarding and reviewing manually from time to time.