KYC refresh and periodic review, worked to your policy
Review cycles by risk tier, with customer outreach, checked evidence and a clear handoff to your compliance team.
Actigy BPO provides KYC refresh through nearshore business process outsourcing (BPO) teams in Bulgaria, Romania, Poland and Ukraine. Operators update customer files, review screening results and prepare periodic reviews under your policy. A process audit and paid pilot define the work. Your compliance team retains risk ratings, customer acceptance and filing decisions.
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Key takeaways
Actigy BPO supports know your customer (KYC) operations without taking over your compliance decisions.
- Actigy BPO delivers from teams in Bulgaria, Romania, Poland and Ukraine.
- Every Actigy BPO engagement starts with a process audit and a paid pilot.
- Scheduled reviews and event-triggered checks need separate queues.
- A prepared file is not a customer approval.
- The client sets the review policy and resolves risk exceptions.
KYC review delivery at a glance
Actigy BPO agrees the file population, access, outreach rules and review owners before work starts.
| Field | Scope |
|---|---|
| Service | Recurring file reviews, document updates, outreach and screening review. |
| Who for | Banks, fintechs and payment firms with approved review procedures. |
| Delivery locations | Bulgaria, Romania, Poland and Ukraine. |
| Coverage | Business hours to 24/7, set per engagement. |
| Pricing model | Per full-time equivalent (FTE) by role, after scoping. |
| Typical start | Pilot usually 2 to 4 weeks after the process audit. |
KYC refresh scope and review triggers
Actigy BPO prepares recurring reviews from the client's approved due dates and risk tiers. Each file retains its policy version, evidence and next owner. Operators compare current records with the required fields. Gaps remain visible until the client accepts the evidence or decides the next action.
| Work type | Trigger and purpose |
|---|---|
| Periodic review | A scheduled date starts a check of existing customer information. |
| Event-driven review | A relevant change starts a review before the next scheduled date. |
| Perpetual KYC | Ongoing signals create targeted checks under an approved monitoring design. |
| Remediation | A defined project repairs missing, outdated or deficient evidence. |
Customer due diligence (CDD) covers the customer and relationship, not just identity documents. Record changed owners, expired evidence and screening alerts.
For a bounded backlog or audit finding, use KYC remediation services. For onboarding and broader review capacity, see KYC outsourcing. Recurring reviews need a sustainable schedule after any backlog project ends.
How Actigy BPO runs periodic reviews
Actigy BPO records the review sequence in a client-approved standard operating procedure (SOP). Training uses accepted files and examples of exceptions. The team lead tracks due dates, missing records and cases awaiting client review. Work expands only after the client accepts the pilot.
- Map the population. Count files by risk tier, due date, entity type and known gaps.
- Agree the procedure. Define required evidence, outreach rules, review checks and escalation owners.
- Train operators. Test sample files before the client approves production access.
- Run the paid pilot. Review a defined file group against the agreed checks.
- Update the records. Request missing information and record changes in approved systems.
- Check the pack. Apply maker-checker quality assurance (QA) and agreed sampling.
- Submit and report. Send prepared files to client reviewers and track returns separately.
How does KYC periodic review outsourcing work?
Actigy BPO runs the approved file queue while your compliance team owns the review policy and decisions. Operators request records, check evidence and prepare review packs. The client accepts risk changes and resolves exceptions. Separate due, overdue, prepared and approved statuses prevent a completed task from hiding an unfinished customer decision.
Customer outreach, screening and missing evidence
Actigy BPO uses client-approved templates and channels to request only the information needed for each review. Contact records show the request, date, response and next action. Repeat requests follow your cadence. Operators do not threaten account closure or invent a deadline to obtain a response.
Screening review records the search inputs, source result and reason for escalation. Conflicting names, ownership records or customer replies go to the named reviewer. A match is not an automatic rejection. Customer non-response remains a tracked exception; the client decides restrictions, extensions or exit.
Actigy BPO keeps outreach and evidence checks in the same case history. A replacement document retains the previous review context. For transaction alerts and broader case preparation, use anti-money laundering (AML) outsourcing. The refresh queue does not replace ongoing transaction monitoring.
What do perpetual KYC operations include?
Actigy BPO can review event-triggered work in client-approved tools and record the evidence behind each change. The client defines which signals trigger a review. Operators investigate exceptions and prepare the handoff. Perpetual KYC is an operating approach, not a promise that software removes periodic checks or regulated decisions.
Review measures you can audit
Actigy BPO reports management information (MI) against a defined file population. Each key performance indicator (KPI) needs a period, denominator and status rule. Count accepted preparation separately from customer approval. Report client-held decisions and missing customer evidence without treating either as a finished review.
| Measure | Definition |
|---|---|
| Due and overdue files | Files approaching or beyond their client-approved review date, split by risk tier. |
| Prepared on time | Review packs prepared by the cutoff divided by packs due in the period. |
| First-review acceptance | Packs accepted without return divided by packs checked, with the sample stated. |
| Outreach response | Responses received against contacted files, separated from responses that resolve the gap. |
| Exception age | Elapsed time awaiting evidence or a named client decision. |
Controls, access and decisions you retain
Actigy BPO works in the client's tools, with access limited to the systems the client approves. Separate preparation and approval rights limit unauthorized changes. Logs identify who changed a field and which source supported the update. Approved automation requires defined data boundaries and human review of exceptions.
The client owns policy, risk ratings, customer acceptance and exit decisions. The team never acts as your money laundering reporting officer (MLRO). Suspicious activity report (SAR) and suspicious transaction report (STR) decisions and filings remain with authorized client staff. No service here provides legal advice.
Actigy BPO flags source conflicts, missing documents and failed imports. Instructions retain their version. Agree access, retention and record handback in the data-processing terms.
What changes for KYC refresh under AMLR?
Actigy BPO works to the client's approved implementation of the EU Anti-Money Laundering Regulation (AMLR). Article 26 sets risk-based update ceilings and event-driven review duties. Those rules do not require annual checks for every customer. Your legal and compliance owners determine applicability and approve the schedule before operators use it.
AMLR Article 26 sets a 1-year ceiling for its specified higher-risk customers and 5 years for others. Relevant changes can require earlier review. General application starts on 10 July 2027, subject to Article 90 exceptions. Read the AMLR 2027 readiness guide for the legal and operational distinction.
Coverage, locations and KYC refresh pricing
Actigy BPO teams in Central and Eastern Europe cover the full UK business day and the US morning. Agree shifts and escalation cover. Location alone does not establish data residency.
EU hubs are in Bulgaria, Romania and Poland. Ukraine is outside the EU. The written scope names work locations, subprocessors and any transfer terms. Your compliance owner reviews outsourcing requirements before access starts.
Actigy BPO prices most services per FTE by role and sends a written quote after the process audit. File count alone is not enough. Risk mix, ownership complexity, source quality, outreach attempts and reviewer workload affect staffing. Use the outsourcing pricing models guide to compare the same scope.
Compare KYC review delivery models
Actigy BPO manages the agreed queue and preparation controls. Compare responsibilities, not just operator rates.
| Decision | Actigy BPO managed team | In-house team | Freelancer or staffing agency |
|---|---|---|---|
| Daily work | Team lead manages the agreed queue. | Your manager directs employees. | Confirm who assigns work. |
| Procedure ownership | Client owns procedures and policy. | Client owns procedures and policy. | Specify ownership and version control. |
| Quality checks | Agreed checks and client review. | Internal review plan. | Confirm checking and correction duties. |
| Risk decisions | Client retains all regulated decisions. | Authorized client staff decide. | Confirm retained decision authority. |
| Coverage hours | Written scope defines shifts. | Internal staffing schedule. | Contracted availability. |
| Typical start | Audit, access, training and pilot. | Hiring and training readiness. | Selection and onboarding. |
| Pricing model | Role-based written quote. | Employment and operating costs. | Contracted fee basis. |
| Exit and handover | Client records and agreed handback. | Internal handover. | Specify records and access return. |
Actigy BPO evidence and fit
Actigy BPO cleared a backlog of 14,000 pending user verifications in an anonymized fintech engagement (Actigy BPO-reported). Read the fintech KYC and AML onboarding case for the delivered scope. The client retained risk policy and final filing decisions.
Results come from anonymized client engagements, are reported by Actigy BPO and are not independently audited. Results depend on scope.
The case concerns onboarding and screening operations, not a refresh-only program or AMLR certification. A new review population needs its own pilot and acceptance criteria.
Actigy BPO fits when scheduled reviews exceed internal capacity, event-driven checks lack owners, or recurring outreach needs a managed queue. A separate remediation plan fits historical file gaps. The client must provide approved procedures and available decision owners.
Actigy BPO is not the right fit when you need legal advice, delegated risk acceptance or a provider to act as your MLRO. A software-only requirement also differs from managed review operations.
KYC refresh FAQ
Actigy BPO separates recurring file preparation from customer approval and regulatory interpretation.
What is a KYC refresh?
A KYC refresh reviews an existing customer's information and updates records under the firm's current policy. Actigy BPO provides file checks, approved outreach, screening review and evidence preparation. A scheduled date or relevant change can start the work. Operators log missing records and unresolved conflicts rather than assuming a file remains accurate.
The client reviews the prepared pack and retains risk ratings, acceptance, restrictions and exit decisions.
How often should KYC be refreshed?
Actigy BPO follows the intervals and event triggers that the client's compliance team approves under applicable rules. Risk tier, changed circumstances and evidence quality affect timing. An interval is not permission to ignore a relevant change before the due date. Keep the policy version and reason for each review in the file.
AMLR-specific ceilings appear above; they are not a worldwide review schedule or a requirement to refresh every customer annually.
What is perpetual KYC?
Perpetual KYC uses ongoing signals to identify customer information that needs review. Actigy BPO provides human review of agreed event-driven tasks in the client's systems. The client defines triggers, evidence requirements and escalation rules. A signal requires investigation; it does not automatically approve or reject a customer.
Tool access, source quality and human review remain necessary. The approach does not remove scheduled checks required by the client's policy or applicable law.
How is KYC refresh different from KYC remediation?
Actigy BPO runs refresh as recurring or event-driven maintenance and remediation as a defined project to repair identified file gaps. A firm can need both. Separate the historical backlog from new reviews so project progress does not hide a growing recurring queue. Assign each population a scope, owner and acceptance rule.
After a remediation project, transfer the remaining schedule and evidence into the ongoing review process without losing earlier case history.
How are KYC refresh services priced?
Actigy BPO usually prices KYC refresh per FTE by role after the process audit. The written quote reflects risk mix, file complexity, outreach, checking and coverage. Include your retained reviewers, systems and transition work when comparing costs. A file count without those details does not define the required team.
The paid pilot tests effort and preparation quality before expansion. No universal price per file or clearance time applies to every population.
Plan a defined review pilot
Actigy BPO can scope a review queue from file counts, risk tiers, due dates and known gaps. Send aggregate information first. Do not include identity documents or customer records in this enquiry form. Agree secure access before sharing case evidence.
Page updates
Actigy BPO published this guide on October 5, 2026, with review responsibilities, evidence checks and linked regulatory sources.
Scope a pilot
What happens next
The team reviews the workflow before proposing a written scope. You decide whether to start a paid pilot after reviewing it.