Propose and approve a KYC change
Change a live customer's KYC details under maker-checker, from the proposal to the approval.
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KYC details on a live customer never change on one person's say-so. One person proposes the change with a reason, and a different authorised person approves it before it takes effect. This article covers both sides.
Before you start
- To propose a change you need the Senior analyst, MLRO, Deputy MLRO, Relationship manager or KYC reviewer role.
- To approve a change you need the MLRO, Deputy MLRO or Senior approver role, and a second factor for step-up.
- You can never approve a change you proposed. FlowSentry shows: "The approver must be a different person from the author (segregation of duties)."
Propose a change
- Find the customer. Use the command palette (Ctrl+K or ⌘K) or the Customers register at
/customers. - On the customer profile, select Edit KYC details, or Edit on the section you want to change (for example identity documents, addresses, contacts or the PEP self-declaration).
- Enter the new value.
- Fill in Reason for the change. Say where the new information came from, for example "Updated ID document provided at branch".
- Select Send for approval.
You will see: "Your change is sent for approval. It applies only when another authorised person approves it." The change now shows as Awaiting approval.
Tip: You can Withdraw your change at any time before it is decided, for example if you spot a typing error.
Approve or reject a change
- Open KYC changes at
/customers/kyc-changes, or open the item from My approvals at/approvals/inbox. The notifications bell also lists items waiting for you. - Open the change. You will see the Field, what is On file, what is Proposed and the Reason.
- Optionally select Review with AI. The assistant summarises what changes, the risk it carries and what to check before approving. It is advisory only.
- Check the change against the evidence.
- Choose one:
- Approve. You will be asked to confirm with a fresh second factor (step-up) if you have not done so in the last five minutes.
- Reject, with a decision note explaining why.
Note: The AI review never approves anything. It does not see full identifiers; for an identifier it only learns whether one was added, replaced or removed.
What happens after approval
- The new details apply to the customer at once.
- The customer is re-screened against your watchlists.
- The field becomes one of the Fields maintained by FlowSentry. Later updates for that field from your core system will not overwrite it.
- Both the proposal and the decision are recorded in the audit trail under the names of the people involved.
Hand a field back to the core system
If the core system should own the field again, use Return to source on the customer's profile. This is itself a governed change and goes through the same approval.
Change statuses
| Status | Meaning |
|---|---|
| Awaiting approval | Waiting for a second person |
| Approved | Applied to the customer |
| Rejected | Declined by the approver, with a note |
| Withdrawn | Taken back by the person who proposed it |
| Superseded | No longer current, because a later change replaced it |
Tips
- Keep the reason factual. The approver and, later, an examiner will read it.
- Required KYC fields for individuals and organisations are set by your administrator in Tenant settings. A customer missing a required item shows as Incomplete.