KYC Remediation Services
Respective File Reviews for Law Firms
At Alexander Christian, we undertake KYC remediation services tailored for regulated law firms. Unlike KYC analyst support — which assists with real-time onboarding and checks — remediation is a retrospective process of looking back, identifying gaps and applying current mitigation. In addition remediation can help your to spot trends in your pre-onboarding, onboarding and ongoing monitoring that need you to address.
What is KYC Remediation?
KYC remediation is the systematic review and correction of client files to ensure they comply with legal, regulatory, and internal AML obligations. It is a vital part of risk management, especially when firms need to:
Undertake look-back screening
Ensure that justification and reasoning can be found on the file
Address outdated or incomplete due diligence
Respond to audit findings
Spot internal trends in your pre-onboarding, onboarding and monitoring implementation that you may need to address
Meet the standards of the LSAG and the Money Laundering Regulations
Why is this important
KYC, CDD and EDD are not one-off events.
Client and matter risk evolves — and your AML records must reflect that. If you're ever required to justify your client risk assessments, matter ratings, or the mitigation steps taken under your firm’s Policies, Controls and Procedures (PCPs), your documentation must be clear, consistent, and readily accessible.
Key reasons why KYC remediation is necessary:
Regulatory justification: You must be able to demonstrate how and why a client or matter was risk-rated, what checks were performed, and how your PCPs were applied in practice.
Record retention: AML documentation must be retained for at least five years from the end of the business relationship or transaction — and must be complete enough to “resurrect” the file if needed.
Identifying and addressing gaps: A remediation review helps identify inconsistencies, missing information, or outdated assessments across your files.
Look-back screening: Regulators and oversight bodies (including the OSTI) have stressed the importance of monitoring and look back screening
Reporting obligations: Your MLRO needs accurate records to fulfil their duties — including making appropriate reports to the NCA, your regulator, or other authorities.
No system is 100% accurate: But having a process to deal with issues helps to strengthen your system
Proactive risk management: It’s better to identify and self-remediate issues than to wait for them to be discovered in a regulatory review or audit.
KYC remediation helps your firm take control of its risk landscape — and reinforces a culture of compliance and accountability.
Our service is bespoke and discussed in full at your scoping meeting.
Why It Matters
- Risk assessments at both client and matter level
- Timely and proportionate due diligence
- Evidence of monitoring and review
- Use of risk-based tools (e.g., sanctions and media checks)
What We Review
We carry out a detailed assessment of your client files and supporting documentation, considering whether:
Client Due Diligence has been obtained, assessed, and documented appropriately
Sanctions screening has been conducted and recorded
Adverse media screening has been performed and escalated if needed
The matter has a completed, tailored Client Matter Risk Assessment (CMRA)
Source of funds and source of wealth are evidenced where applicable
Ongoing monitoring and refresh procedures have been followed
Each file is checked against your firm’s FWRA and internal PCPs — not just generic standards — ensuring remediation is realistic and compliant within your existing framework.
This service is bespoke and discussed during your scoping meeting.
When Should You Use KYC Remediation?
Risk management is not a one-off task — it’s a continuous cycle of review, action and improvement.
KYC remediation may be appropriate when:
Legacy files need reviewing: Older or archived matters may not meet current AML standards or reflect recent updates to your firm’s PCPs.
There’s a backlog of due diligence: With the pace of legal work, it’s easy for periodic reviews to fall behind — particularly in busy practices. Remediation helps restore control.
You're conducting a firm-wide file review: As part of an internal audit cycle, quality assurance programme, or thematic risk review.
Following a Mock Audit or Regulation 21 Audit: To address issues identified and demonstrate active steps toward remediation.
You're responding to a regulatory remediation plan: Where the SRA or another body has required a structured response.
To support policy or training improvements: Remediation findings can be used to refine your risk assessment framework, highlight training gaps, and improve your AML controls overall.
In short, KYC remediation helps you look back — so you can move forward with confidence.
KYC Support vs KYC Remediation – What’s the Difference?
KYC Support and KYC Remediation are distinct but complementary services:
| KYC Support | KYC Remediation |
|---|---|
| Focuses on day-to-day file opening, onboarding, risk rating and verifying clients in line with your firm’s FWRA and PCPs. | Reviews existing or historic client files to identify gaps, inconsistencies or missing risk documentation. |
| Often used during periods of high demand (e.g. onboarding surges, audits, or staff shortages). | Often used after audits, during quality assurance reviews, or when preparing to report or respond to a regulator. |
| Helps you meet your current AML obligations and maintain momentum with live matters. | Helps you correct legacy issues and ensure your records stand up to scrutiny. |
| Hands-on compliance resource working within your framework. | Forensic-style review and clean-up of your AML file estate. |
Confidential, Experienced, Practical Support
If you're concerned about legacy KYC compliance, we're here to help.
Contact us for a confidential conversation.