refresh

name	refresh
description	Periodic customer refresh with re-verification of original due diligence to detect material changes and maintain compliance with ongoing due diligence requirements. Triggers include time-based review (annual HIGH risk, 2-3 year intervals for MEDIUM/LOW), risk-based escalation (score changes, business pivots), and event-based alerts (sanctions, adverse media, regulatory actions).
user-invocable	true
category	compliance
estimated-duration	45 minutes

Customer Refresh Skill - v1.0.0

Periodic customer review with independent re-verification to maintain ongoing due diligence compliance and detect material changes.

Overview

Refresh is mandatory continuing monitoring required under AMLD5 (UK/EU), FinCEN CDD Rule (US), and MENA regional regulations. This skill re-runs the Step 0 onboarding verification framework to establish whether material changes have occurred and risk profile remains appropriate.

Key Principle: Refresh detects what changed, not what was previously found.

Why Refresh Matters

Regulatory frameworks across all jurisdictions mandate ongoing monitoring because:

1. Risk Emergence: Beneficial ownership, regulatory status, and threat profiles evolve. A low-risk business can pivot to high-risk sectors; transparent ownership can become hidden.

2. Sanction Exposure: Designation lists update monthly. Customers or their beneficial owners may become PEPs, fall under sanctions, or face criminal charges.

3. Adverse Media Detection: News of regulatory enforcement, criminal convictions, or corruption allegations may not appear during onboarding but emerge later.

4. Beneficial Ownership Verification: AMLD5 and FinCEN BOI Rule require periodic confirmation that beneficial ownership information remains accurate and complete.

Refresh Intervals by Risk Category

See detailed regulatory requirements:

• UK/EU: regulations-uk-eu.md
• MENA: regulations-mena.md
• US: regulations-us.md

Quick Reference:

• HIGH: Annual (all regions)
• MEDIUM: 24 months (UK/EU), 6 months (MENA)
• LOW: 36 months (UK/EU), 12 months (MENA/US)

Refresh Triggers

See complete trigger library: refresh-triggers.md

Types of Triggers:

• Time-based: Scheduled per risk category
• Risk-based: Customer risk score change, business model shift, regulatory classification change
• Event-based: Sanctions alert, adverse media, regulatory enforcement, MLRO escalation closure

Step-by-Step Refresh Procedure

Step 1: Initiate Refresh [HITL Checkpoint]

Analyst Actions:

1. Open customer profile and verify last refresh date vs. risk category
2. Confirm trigger: Time-based, risk-based, or event-based (document in case file)
3. Export original onboarding report to compare findings
4. Review original 5 searches performed at Step 0 onboarding:
   • Search 1: Google/LinkedIn/Business Registry (public profile, business interests)
   • Search 2: Sanctions/Regulatory (OFAC/PEP databases, regulatory records)
   • Search 3: Adverse Media (news, adverse events, regulatory actions)
   • Search 4: Corporate Records (ownership structure, filings, director changes)
   • Search 5: Financial Risk (credit reports, industry risk indicators, market data)

Manager Checkpoint:

• Confirm refresh is timely (not premature, not overdue)
• Verify trigger is documented and justified
• Approve proceeding to Step 2

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Step 2: Re-Run 5 Independent Searches [HITL Checkpoint]

Repeat exact searches from onboarding to establish fresh baseline.

Search 1: Public Profile & Business Interests

• Google search: Customer name + company name
• LinkedIn profile review
• Company registry filings (Companies House UK, SEC Edgar US, local registries)
• Business database review (Bloomberg, Crunchbase, business.gov.uk)
• Compare to original: New directorships? Business pivots? Changed sectors?

Search 2: Sanctions & Regulatory Databases

• OFAC SDN List (US)
• EU Sanctions Lists
• UK Office of Financial Sanctions Implementation (OFSI)
• UN Consolidated Sanctions List
• INTERPOL Red/Yellow Notices
• Compare to original: Any new matches? Designations on family members?

Search 3: Adverse Media Review

• Google News search (5-year lookback)
• Reuters/Bloomberg news terminals
• Adverse media monitoring service (LexisNexis, World-Check, Refinitiv)
• Regulatory enforcement databases
• Criminal record databases (jurisdiction-specific)
• Compare to original: New media coverage? Regulatory actions? Criminal charges?

Search 4: Corporate Structure & Beneficial Ownership

• Company registry beneficial ownership filings
• Corporate structure diagrams (if available from data providers)
• Director and shareholder searches
• Related entity searches (common shareholders, directors)
• Ownership chain verification
• Compare to original: New beneficial owners? Changes in shareholder structure? Hidden beneficial ownership patterns?

Search 5: Financial Risk Indicators

• Credit report review (if available and permitted)
• Financial viability indicators (industry reports, market data)
• Industry risk assessment (sector risk changes?)
• Geographic risk mapping (new operations in high-risk jurisdictions?)
• Transaction pattern baseline (if monitoring data available)

Analyst Documentation:

• Record all 5 searches with dates, platforms used, search terms
• Screenshot or document key findings
• Note "No new findings" vs. "New findings" for each search

Manager Checkpoint:

• Confirm all 5 searches were completed
• Verify search methodology matches original onboarding
• Approve moving to Step 3 (change comparison)

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Step 3: Identify Material Changes [HITL Checkpoint]

Compare refresh findings to original onboarding findings.

Material Changes (Automatic Escalation):

1. Beneficial Ownership Changes

   • New beneficial owner with 25%+ stake
   • Beneficial owner departure (25%+ stakeholder)
   • Evidence of beneficial ownership concealment
   • Change to nominee or trust ownership structure
   • Action: ESCALATE to Manager + MLRO

2. Business Structure Changes

   • Corporate restructuring (merger, acquisition, restructure)
   • Business sector pivot to high-risk sector (crypto, gambling, trade finance, weapons)
   • Loss of regulatory status or license
   • Action: ESCALATE to Manager + MLRO

3. Regulatory Changes

   • Customer becomes regulated entity (escalate for new due diligence)
   • Customer loses regulatory authorization
   • Regulatory enforcement action against customer or principals
   • Action: ESCALATE to Manager + MLRO

4. Sanctions & Adverse Media Changes

   • Sanctions designation (any customer or beneficial owner)
   • Adverse media: regulatory enforcement, criminal conviction, corruption allegation
   • INTERPOL or criminal investigation listing
   • Action: IMMEDIATE ESCALATION (same-day MLRO notification)

Non-Material Changes (Risk Assessment Update):

• Address change within expected geographic scope
• Standard corporate governance changes (board rotation, officer changes)
• Business expansion within same risk sector
• Beneficial ownership updates confirming prior findings

Analyst Documentation:

• List all findings (new and unchanged)
• Flag each finding as "Material Change" or "Update"
• For material changes: document source, date discovered, risk implication
• For updates: brief note confirming prior findings still valid

Manager Checkpoint:

• Confirm change classifications (material vs. non-material)
• Verify material changes are documented with source evidence
• Determine escalation path (Manager review, MLRO notification, immediate quarantine)

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Step 4: Risk Re-Assessment [HITL Checkpoint]

Update customer risk category based on refresh findings.

Risk Categories:

• HIGH: PEPs, beneficial owners of complex structures, high-value customers, high-risk sectors, frequent transactions to high-risk jurisdictions, family of sanctions targets
• MEDIUM: Established businesses in moderate-risk sectors, some international activity, standard corporate governance
• LOW: EU regulated entities, transparent ownership, narrow scope of business, domestic focus, established markets

Reassessment Decision Tree:

1. Were any MATERIAL CHANGES found? → ESCALATE (see Step 3)
2. Do new findings increase risk? → Upgrade risk category or maintain current level
3. Do any findings decrease risk? → Consider downgrade (documented justification)
4. No material changes found → Confirm existing risk category with brief note

Documentation:

• Current risk category (HIGH, MEDIUM, LOW)
• Reassessed risk category (if changed)
• Justification for any risk category change
• Next refresh date per new risk category

Manager Checkpoint:

• Review risk assessment rationale
• Confirm risk category is appropriate for findings
• Approve risk decision and next refresh schedule

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Step 5: Material Change Escalation (If Applicable)

When to Escalate:

All material changes from Step 3 require escalation. Route to:

• Manager: For review and oversight (all escalations)
• MLRO (Money Laundering Reporting Officer): For determination of SAR-reportability (US) or regulatory reporting (UK/EU/MENA)

Escalation Urgency:

• IMMEDIATE (same-day): Sanctions designation, criminal charges, evidence of beneficial ownership concealment
• PRIORITY (24-48 hours): New beneficial owners, business pivots to high-risk sectors, regulatory enforcement actions
• STANDARD (1 week): Material ownership changes, loss of regulatory authorization, substantial adverse media

Manager Actions:

1. Review refresh findings and material change determination
2. Assess customer account risk and transaction history
3. Determine if SAR/suspicious activity reporting required
4. Decision: Escalate to MLRO, escalate to compliance team for investigation, or route to specialized unit

MLRO Actions:

1. Evaluate suspicious activity pattern (if Manager refers)
2. Determine regulatory reporting obligation
3. Determine account actions: monitoring enhancement, transaction review, account closure review
4. Document decision and rationale in case file

Post-Escalation:

• Account placed on enhanced monitoring pending resolution
• Next refresh scheduled after escalation resolved and account decision made

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Step 6: Generate Output & Schedule Next Refresh

Output Template: Use locked template from OUTPUT_TEMPLATES/refresh-report.md

Refresh Report Contains:

• Refresh initiation date and trigger
• Summary of 5 searches conducted (platforms, dates)
• Key findings from each search (new and unchanged)
• Comparison table: Original onboarding vs. refresh findings
• Material change determination (yes/no, what changed)
• Risk category re-assessment with justification
• Escalation decision and routing (if applicable)
• Manager sign-off with name, date
• MLRO referral summary (if escalated)
• Next refresh date scheduled

Case File Updates:

• Attach refresh report to customer case file
• Link to original onboarding findings for comparison
• Update customer profile with new information (address, beneficial owners, regulatory status)
• Update risk category and next refresh date in system

Schedule Next Refresh:

• HIGH risk: 12 months from refresh date
• MEDIUM risk: 24 months from refresh date (36 months for HIGH if reassessed to MEDIUM)
• LOW risk: 36 months from refresh date
• Set system reminder for 30 days before due date

Manager Final Checkpoint:

• Refresh report complete and accurate
• Case file updated with findings
• Next refresh date scheduled appropriately
• Escalations routed correctly (if applicable)
• Archive refresh documentation per retention requirements

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Material Change Examples

Scenario 1: Business Pivot (Material Change)

Original: Business consulting firm, LOW risk, 3-year refresh cycle Refresh finds: Company now offers crypto trading services and investment management Analysis: Business pivoted to high-risk sector (crypto) without prior disclosure Action: ESCALATE - Material change, risk reassessment required (likely HIGH)

Scenario 2: Beneficial Owner Change (Material Change)

Original: Family-owned business, clear beneficial ownership, MEDIUM risk Refresh finds: New beneficial owner acquired 30% stake via offshore entity, beneficial ownership structure now opaque Analysis: Beneficial ownership changed materially, transparency decreased Action: ESCALATE - Investigate new beneficial owner, determine if concealment patterns present

Scenario 3: Regulatory Action (Material Change)

Original: Financial services firm with valid licenses, MEDIUM risk Refresh finds: Regulatory authority issued enforcement action for compliance failures; CEO charged with fraud (media alert) Analysis: Regulatory status changed; principals now under criminal investigation Action: IMMEDIATE ESCALATION - Contact MLRO for SAR evaluation and account disposition

Scenario 4: No Material Changes (Update Only)

Original: E-commerce business, transparent ownership, MEDIUM risk Refresh finds: Address moved within same city; new CFO on board; annual revenue growth documented Analysis: No material changes to beneficial ownership, business model, or regulatory status; governance updates are normal Action: CONFIRM risk category, document findings, schedule next refresh per 24-month interval

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Regional Compliance Notes

Refresh requirements vary by jurisdiction. See detailed guidance:

• UK/EU: regulations-uk-eu.md - AMLD5 compliance, annual HIGH risk
• MENA: regulations-mena.md - Enhanced QUARTERLY for HIGH risk per UACB/SAMA
• US: regulations-us.md - FinCEN CDD rule, annual HIGH risk

Multi-Jurisdictional Customers: Apply most stringent requirement. If customer operates in both UK and US, use annual refresh interval (both jurisdictions require annual for HIGH risk).

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Locked Output Template

Use: /OUTPUT_TEMPLATES/refresh-report.md

Ensures consistent documentation and audit trail compliance.

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Version: 1.0.0 Last Updated: 2026-02-12 Author: Vyayasan Regulated: AMLD5 (UK/EU), FinCEN CDD Rule (US), UACB/SAMA (MENA)

MCP Integration: Uses same ~~browser, ~~excel, ~~pdf connectors as onboarding workflow. See CONNECTORS.md.