BPO Service

KYC remediation services: fix deficient files and clear the backlog

A trained analyst team refreshes customer files to your policy, with QA and evidence your auditors can follow.

Direct answer

Actigy BPO provides KYC remediation as a nearshore business process outsourcing (BPO) company headquartered in Prague, Czech Republic. Operators correct know your customer (KYC) file gaps against client policy and prepare review packs. A process audit sets priorities before a paid pilot tests the method. The client retains risk ratings, acceptance and exits.

Define the customer population, file standard and client decision owner before transferring a queue.

Key takeaways

Actigy BPO prepares evidence; the client makes customer decisions.

  • Every Actigy BPO engagement starts with a process audit and a paid pilot.
  • Actigy BPO works in the client's tools, with access limited to the systems the client approves.
  • Separate completed packs, pending evidence and customer decisions.
  • Keep risk ratings, regulatory filing and exits with the client.

KYC remediation at a glance

Actigy BPO prepares customer due diligence (CDD) and enhanced due diligence (EDD) files to client policy. Quality assurance (QA) checks the evidence.

Actigy BPO KYC remediation scope and engagement terms
ServiceFile review, missing evidence, screening review and packs
Who it is forBanks, fintechs and payment firms with backlogs
Delivery locationsBulgaria, Romania, Poland and Ukraine; the first three are European Union (EU) hubs
CoverageBusiness hours to 24/7, set per engagement
Pricing modelPer full-time equivalent (FTE) by role; written quote after the process audit
Typical startPilot usually 2 to 4 weeks after the process audit; access, training and approvals affect timing

KYC refresh vs KYC remediation

Actigy BPO separates file repairs from routine updates and scheduled reviews. Remediation corrects gaps against the client's standard.

KYC remediation vs refresh vs periodic review: Actigy BPO scope guide
CheckActigy BPO remediationRefreshPeriodic review
TriggerIdentified file deficiencyChanged or outdated informationClient's review cycle
ScopeAgreed deficient-file populationAffected information and checksPolicy-defined relationship review
DurationBased on file gapsDepends on the updateClient-defined cycle
OutputEvidence pack and unresolved exceptionsUpdated records and evidenceReview record for client decision

Actigy BPO can review files after audits, policy changes, system moves or customer-book purchases. Evidence supports anti-money laundering (AML) controls, not assured crime prevention or regulatory approval.

How Actigy BPO runs a KYC remediation project

Actigy BPO agrees standard operating procedures (SOPs), thresholds and escalation owners. Selected operators train on approved examples.

  1. Scope the population. Review sample files in the process audit; record client risk-based priorities.
  2. Define the gaps. Compare fields and evidence with policy; train on accepted and disputed examples.
  3. Test the queue. Run a paid pilot with agreed QA and key performance indicator (KPI) definitions.
  4. Request missing records. Use client-approved outreach templates, channels and contact rules.
  5. Review identity and ownership. Check documents, identity verification and ultimate beneficial owner (UBO) evidence within approved tools.
  6. Review screening evidence. Record sanctions, politically exposed person (PEP) and adverse-media findings; escalate doubts.
  7. Check and deliver. Check with a second reviewer; record exceptions and expand only after client pilot acceptance.

CDD remediation project plan

Actigy BPO records each file's risk tier, policy version and next owner. Review repeat defects before changing instructions. Separate preparation from missing evidence and pending client decisions.

Customer outreach and non-response

Actigy BPO uses client-branded templates and approved channels to request missing evidence. The client's SOP sets the cadence, deadline wording and escalation route.

Operators request only needed data. Log contacts and replies in approved systems. Return conflicting replies to review.

Actigy BPO sends unanswered requests and open gaps to the client's named owner. Clear messages support customer trust; the client decides restrictions or exits.

Data accuracy and common remediation challenges

Actigy BPO checks fields and applies four-eyes review under the QA plan. Each pack records sources, checks, reasons, gaps and pending decisions.

Remediation challenges and Actigy BPO preparation controls
ChallengeOperational responseClient escalation
Customer non-responseRecord attempts and missing evidenceClient decides restrictions, extensions or exits
Poor source dataCheck conflicting fields against source recordsClient resolves unavailable or unacceptable evidence
Changing policyVersion instructions and identify affected filesPolicy owner approves revisions
Manual workloadGroup tasks and record repeat defectsClient approves tool or process changes
Deadline pressureReport capacity and blocked work separatelyClient approves priorities; no skipped checks

How to clear a KYC backlog

Actigy BPO reports accepted packs separately from pending evidence or client decisions. Count closure only against the agreed quality standard.

Actigy BPO remediation management information and progress measures
MeasureDefinition
Backlog burn-downOpening files plus new arrivals minus accepted closures
Completion by risk tierAccepted closures within each client-defined tier
Exception agingTime unresolved items await evidence or a named decision
Quality control (QC) pass rateReviewed files meeting the agreed standard, divided by files checked
QA defectsErrors by type, policy version and batch
Files closed per weekAccepted preparation packs; not customer approvals

Client systems, screening tools and data handling

Actigy BPO uses client screening, document and case tools with approved access. Record source evidence and case history there.

At Actigy BPO, automation or AI runs only where the written scope approves it, with human review of every exception. Artificial intelligence (AI) does not replace human file review or client decisions.

Actigy BPO uses access limits, logs and separate preparation and approval rights. Agree data minimization, retention and record return in the data-processing terms. Review the security practices before transferring records.

Actigy BPO uses ISO 9001-aligned quality management. Aligned, not certified. SOC 2-aligned controls: role-based access, logging and segregation of duties. Aligned, not audited.

What stays with your MLRO

Actigy BPO prepares files for your money laundering reporting officer (MLRO) and named reviewers. The client approves risk ratings, EDD, acceptance and exits.

Suspicious activity report (SAR) and suspicious transaction report (STR) decisions remain with your authorized staff. Actigy BPO prepares KYC reviews; the client keeps final risk acceptance and SAR or STR filing. The team never acts as your MLRO or gives legal advice.

EU AMLR timing and client policy

Actigy BPO prepares reviews against the client's approved policy, not its own legal interpretation. Article 90 of Regulation (EU) 2024/1624 sets general application from 10 July 2027.

The EU Anti-Money Laundering Regulation (AMLR) applies directly across member states. Article 90 sets 10 July 2029 for the entities specified in Article 3(3)(n) and (o). Your legal and compliance owners determine applicability and approve any operational changes.

KYC remediation vendors in Europe

Actigy BPO delivers from teams in Bulgaria, Romania, Poland and Ukraine. Bulgaria, Romania and Poland are EU hubs; Ukraine is outside the EU. The written scope names work locations, subprocessors and any transfer terms.

Actigy BPO teams in Central and Eastern Europe cover the full UK business day and the US morning. Confirm shifts and client review cover; location does not replace controls.

How Actigy BPO prices KYC remediation

Actigy BPO prices most services per FTE by role and sends a written quote after the process audit. Compare the same risk mix, outreach and review effort.

Actigy BPO managed remediation compared with other delivery models
ResponsibilityActigy BPO managed teamIn-house teamFreelancer or staffing agency
Daily managementAgreed team leadClient managerConfirm supervision
SOP ownershipClient-ownedClient-ownedConfirm control and versions
Quality reviewAgreed QA; client decisionsClient review systemConfirm review owner
CoverageScoped shiftsInternal scheduleContracted availability
StartAudit and paid pilotHiring and training readinessSelection and onboarding
PricingPer FTE by roleEmployment and operating costsContracted fee basis
ExitAgreed records and access handbackInternal handoverAgreed records and handback

Actigy BPO fits when a firm has a periodic-review backlog, audit-identified file gaps or an overloaded screening-review queue. Actigy BPO is not the right fit when you need an MLRO, legal advice or delegated risk acceptance.

Evidence from a fintech onboarding backlog

Actigy BPO cleared a backlog of 14,000 pending user verifications for an anonymized fintech client (Actigy BPO-reported). The onboarding case is not a forecast for file remediation.

Results come from anonymized client engagements, are reported by Actigy BPO and are not independently audited. Results depend on scope.

Read the fintech KYC and AML case study for the original scope and retained client authority.

KYC remediation FAQ

What is KYC remediation?

KYC remediation is a project that corrects gaps in existing customer files against an agreed policy standard. Actigy BPO provides file review, evidence collection and decision-ready records under the client's instructions.

Remediation differs from routinely updating information or completing a scheduled review. Define the files, evidence and closure rules before work starts. A complete pack does not approve a customer or transfer risk acceptance.

What triggers a KYC remediation project?

Actigy BPO can support a defined remediation queue after audit findings, policy changes, migrations or the acquisition of a customer book. A trigger identifies gaps, not the same action for every file.

Your policy owner sets the population, priorities and evidence standard. Separate incomplete records from files awaiting a client decision. New rules can prompt review; your advisers decide the legal response.

How long does KYC remediation take?

Actigy BPO estimates the plan from sample files, evidence gaps, priorities and client review capacity. Customer response times and policy exceptions affect completion. No fixed duration applies to every backlog.

Actigy BPO tests the workflow in a paid pilot before increasing volume. Track accepted files, newly discovered gaps and time awaiting decisions separately. Faster preparation does not replace client approval or justify closing an unresolved file.

Who makes the final risk decision on each file?

Actigy BPO prepares the evidence; your authorized compliance reviewers approve risk ratings, enhanced due diligence outcomes, acceptance and exits. The team does not act as your MLRO. Regulatory report decisions and filing stay with the client.

Name the decision owner and escalation route for each file type. Operators record questions, not approve exceptions. A case marked ready for review is not an approved customer relationship.

How do you contact customers for missing documents?

Actigy BPO contacts the client's customers only through approved templates and channels. The client controls the message, requested records and outreach cadence. Operators explain missing items without inventing legal deadlines.

Request only the information needed for the agreed check. Log each contact, response and unresolved gap in the client system. If a customer does not respond, follow the escalation path. The client decides restrictions or exits.

What changes for KYC under the EU AMLR in 2027?

Actigy BPO can prepare file reviews against the policy your compliance owners approve for the AMLR. Article 90 sets general application from 10 July 2027 and a 2029 exception for specified entities. The regulation applies directly across EU member states.

Your legal and compliance owners turn the firm's requirements into work instructions. Confirm files, evidence and escalation rules with those owners.

How are KYC remediation services priced?

Actigy BPO prices remediation per full-time equivalent (FTE) by role after the process audit. File volume, risk mix, evidence gaps and review depth shape the team.

Actigy BPO measures the actual task mix in a paid pilot. Compare cost per accepted preparation pack only after defining acceptance, rework and client review costs. That measure is not a per-file fee or risk approval.

What happens when customers do not respond to remediation outreach?

Actigy BPO records attempted contacts, missing evidence and the time since the last response. The team follows the client's approved cadence and routes unresolved cases to the named owner.

Your policy and authorized reviewers determine any restriction, extension or exit. Separate waiting files from completed files in the report. Keep the contact history so the client can review each action.

Actigy BPO separates this project from ongoing KYC outsourcing and AML alert review. Explore banking operations, fintech compliance operations and the guide to reducing compliance risk.

Page updates

October 4, 2026: published file-remediation scope, outreach, evidence controls and verified AMLR timing.

Test a defined file population

Actigy BPO reviews a sample before proposing the remediation scope. Share the gap standard and named client decision owners.

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.

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