Chasing incomplete KYC checks

Overview

"Incomplete" covers two situations that need different handling.

Not yet done. The participant was invited and has not finished. Nothing is wrong; they need reminding. Use Remind.

Done but not acceptable. They submitted, and something is missing, expired or inconsistent. This needs marking incomplete with a reason, which returns it to them with those reasons attached.

The dashboard distinguishes these by status, so read it before chasing indiscriminately.

What you'll learn

• How to tell reminding from returning

• The reasons you can record

• Who sees those reasons, and why that makes the selection worth care

• Why to record one even though the software says it is optional

Steps

1. From the project Dashboard, open the process under Active Operations. On its KYC dashboard, identify the outstanding cases. Sort or filter rather than reading everything.

2. For someone who has not submitted: Remind. In bulk where several are outstanding.

3. For a submission that is not acceptable: open it, then set it to incomplete.

4. In "Why is this KYC incomplete?", select every applicable reason. Save.

5. The reasons travel back with the task, so the participant can see what to fix. Contact them as well where the case is delicate or they are likely to struggle.

6. When they resubmit, review again (A7.4) and approve (A7.6).

The reasons you can record

For a natural person:

• The information provided is inconsistent with the submitted documents or declared identity details

• Required information is missing from the KYC check submission

• No identity document has been provided

• No proof of address has been provided

• The identity document provided has expired

• The proof of address provided has expired or is no longer valid

For a legal entity, additionally:

• No company registration document has been provided

• The certificate of incorporation provided has expired or is outdated

• No register of beneficial owners document has been provided

• No identity document has been provided for one or more legal representatives

• No identity document has been provided for one or more beneficial owners

You can select more than one.

Who sees the reasons

Both sides do, and the participant's side is the one that matters most.

When the check returns, their portal opens on a warning headed KYC Information Incomplete, listing the reasons you selected, and asks them to go through the process again correcting each one.

So the list you tick is the instruction they read. Three things follow:

1. Select every reason that applies, not just the first one you noticed. They will fix what the list shows and resubmit. A reason left off comes back as a second return.

2. The wording is fixed, so supply the specifics yourself. "No proof of address has been provided" does not say which document you rejected or why. A short message or a call alongside the return costs little and saves a round trip.

3. It is a record for your team too. The next person opening this check sees what happened without having to ask you.

And where a participant cannot get through it even with the reasons in front of them, you do not have to keep returning it: take the check over and complete it internally (A7.3).

Optional in the software, mandatory in practice

The dialog permits saving with no reason at all, and says so. Treat a reason as required anyway: a check returned without one tells the participant that something is wrong and nothing about what — so they guess, resubmit the same thing, and your team diagnoses it a second time.

Reasons can be revised later, via Update incomplete reasons.

What good looks like

No check sits outstanding without either a reminder having been sent or a reason having been recorded. Anyone on the team can open the dashboard and see not just what is unfinished but why — which is the difference between a tracker and a record.

Common problems

You do not know whether to remind or return. Read the status. Anything short of Submitted means they have not finished — remind. Submitted means it is your judgement — review, then approve or return.

A check has been returned twice and is still wrong. Consider whether the participant can complete the digital process at all. If not, an internal check (A7.3) is the answer rather than a third attempt.

A reason no longer applies. Use Update incomplete reasons rather than leaving a stale reason on the record.

Everything is outstanding and nobody has been reminded. The dashboard exists so the team can focus on the incomplete and outstanding cases without keeping a separate compliance list. If a parallel list is still being maintained, something here is not being used.

Related

• A7.4 — Simple KYC checks · the status ladder these decisions read from

• A7.6 — KYC: approve, then verify · the other way out of a submission

• A7.3 — Internal KYC checks · the escape route for a participant who cannot complete

• A7.2 — Launching KYC checks and tracking them · reminding in bulk