Almost every organisation that has run client relationships for years has a book that no longer meets today’s standard. Documents have expired, structures have changed, risk classifications date from another era. KYC remediation is the project that brings this book up to date in an orderly way.
Typical triggers
New regulations, such as the revision of the Swiss Anti-Money Laundering Act in force since 1 October 2026 or the TJPG. Findings from an SRO audit or external audit. Taking over a client book from another firm. A system migration that reveals how patchy the data is. Or the realisation that periodic reviews have not happened for years.
Prioritise by risk
A book cannot be remediated all at once. The order follows the risk-based approach: first higher-risk relationships, then those with the largest gaps, then the rest. For each group, define what counts as complete and set a deadline. Without that definition, remediation becomes a permanent task without an end.
The process per relationship
Inventory: what is there, what is missing, what is outdated? Outreach: a clear list with reasons and a deadline, instead of a general request for documents. Review: received documents against requirements, including sanctions and media screening. Reassessment of risk. Closure with date and responsible person.
When clients don’t cooperate
Not all clients deliver. For that case a rule is needed in advance: reminder, escalation, restriction of the relationship and ultimately termination. The decision is uncomfortable, but it is part of the due diligence duty. A relationship whose documentation cannot be completed is a risk to be carried deliberately or ended, not one to be forgotten.
Documentation and sustainability
In the end, evidence counts: which relationship was remediated when, with what result. A clean audit trail spares reconstruction at the next audit. And so that remediation need not be repeated every few years, the process should afterwards turn into ongoing review with fixed rhythms and triggers.