KYC remediation data quality checklist

Which requirement does a missing field reflect?

Start with the institution, customer type and applicable US rule. FinCEN’s CDD Rule includes exclusions and exceptions for covered financial institutions.

FIN-2026-R001 permits limiting beneficial-owner checks to first account opening, reliability doubts and risk-based ongoing CDD circumstances. Other applicable obligations remain.

The tool cannot decide whether relief applies. An internal review interval is not automatically a universal legal deadline.

Worked example. A contradictory completion status

Fictional example. Customer C-104 is marked “review complete”, but the completion date and control-person evidence reference are blank.

Flag the contradiction. Do not invent a date or copy another customer’s person to make the row pass.

The case owner locates review evidence and explains the missing field. Preserve the original row, proposed change and reviewer decision.

If a requirement does not apply, record the reviewed basis. “Not applicable” without evidence cannot explain an exception to a later reviewer.

Validate the required structure

Confirm stable identifiers, customer type, identity fields, beneficial ownership, risk fields, review dates and evidence references.

Detect contradictions and staleness

Flag conflicting dates, missing control persons, expired evidence, inconsistent country fields and values that cannot be assessed from the supplied record.

Route remediation

Assign each issue, required evidence, priority, decision owner and closure evidence. Keep the final customer and suspicious activity decision outside the mechanical validator.

Working checklist and fictional samples

Use this checklist as an operating aid, not an exhaustive legal assessment. Inspect the samples before entering your own facts.

• Check stable customer identifiers and consistent customer types.
• Check identity and ownership fields for the confirmed route.
• Find invalid dates, incoherent statuses and missing evidence references.
• Assign duplicate, missing and conflicting records issue references.
• Set an owner, priority and required evidence for each action.
• Approve corrections separately from risk, suspicious-activity and account decisions.

• Fictional US KYC validation PDF. Inspect a data-quality report, not a customer-risk or acceptance decision.
• Fictional corrected US KYC workbook XLSX. Review the output structure without using live customer information.