KYC refresh orchestrator
Orchestrates periodic KYC/KYB refresh cycles — schedules due reviews by risk tier, prepares document-request checklists, tracks collection status, chases outstanding items, and escalates approaching-deadline cases. Use when the user mentions KYC refresh, periodic review, customer due diligence cycles, document collection for compliance, or KYB re-verification.
KYC refresh is a deadline machine wearing a relationship costume: hundreds of accounts, each on its own risk-tier clock, each needing the right documents requested, received, verified, and filed — and every missed deadline is a regulatory finding with a customer attached. This skill runs the machine: the calendar, the checklists, the chasing, the escalation. Humans do the verification judgment; the orchestration stops depending on heroics.
When to run
- Continuous: the refresh calendar runs on risk-tier cycles (recommended)
- On demand: "what refreshes are due this quarter" / regulator-driven off-cycle review
Computer scopes
- Compliance system sync: customer risk tiers, last-review dates, review requirements per tier
- Docs: the KYC policy — tier cycles, required documents per customer type, escalation ladder (the rulebook)
- CRM: account owners and customer contacts of record
- Case store: refresh cases, document status, correspondence log (write, gated sends)
Workflow
- Maintain the horizon: accounts entering their refresh window by tier cycle, with the regulatory due date and the internal buffer date both computed — work to the buffer.
- Per case, generate the document checklist from policy for that customer type and tier; pre-fill what current records already satisfy, so customers are asked only for what's actually needed — minimum friction is also minimum error.
- Draft the outreach sequence (initial request, reminders on policy cadence) for the account owner's approval; sends go through configured channels at L1, promotable to L2 for reminder steps only, never for the initial request.
- Track receipt: log arriving documents against the checklist, flag quality problems (expired, illegible, wrong entity) for human verification — the skill tracks completeness, humans judge validity.
- Escalate on the policy ladder: approaching-buffer cases to the compliance queue, approaching-regulatory-deadline cases to the named escalation owner, with full case status.
- On completion, file the case record with dates and document manifest to the audit trail; report cycle metrics monthly.
Guardrails
- Autonomy: L1 for customer-facing sends (initial requests always human-approved); L2 allowed for reminder cadence and internal tracking. Verification judgments and any account-status consequence (restriction, exit) are entirely human and outside this skill.
- Collected documents route only to the compliance store; no identity documents in chat, email bodies, or notifications — links to the secure case, always.
- Deadline math is auditable and conservative; the skill never marks a case complete — humans close cases.
Output
The refresh horizon (account, tier, due/buffer dates, status) → per-case checklists and approved outreach → receipt tracking with quality flags → escalations per ladder → monthly cycle metrics and audit-ready case files.Eval fixtures
- Set: sandbox book of 60 accounts across 3 risk tiers with seeded review histories, including 6 approaching-deadline cases, 8 pre-satisfiable document items, and 5 seeded quality-problem documents.
- Rubric: horizon and deadline math exact; checklist minimality (pre-satisfied items not re-requested); all escalations fire on ladder; quality flags raised, validity never self-judged; zero documents outside the secure store.
- Ship gate: deadline errors 0; escalation compliance 100%; re-request rate on satisfied items 0.
