Use case

Trigger-Event Review

The events that should reopen a customer file, and what to do when one fires. Change of control, a jurisdiction that becomes sanctioned, a name that appears in the press. None of them arrive on a schedule.

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When a file reopens

Triggers do not queue, and they do not arrive in order.

  1. UnscheduledSomething changesOwnership, jurisdiction, behaviour, or the customer's name appearing somewhere it did not before.
  2. Unknown durationBefore you detect itThe interval between the change occurring and your firm seeing it. Detection sources, not review dates, decide how long this is.
  3. On detectionAssess materialityWhether the change bears on the risk rating, or is a change that simply happened.
  4. Where warrantedReopen and re-rateRefresh the file, move the rating if the change justifies it, and record the reason.
Any of these can fire
  • Change of ownership or control
  • Jurisdiction becomes sanctioned or high risk
  • Adverse media above threshold
  • A new director, trustee or signatory
  • Behaviour outside the customer's established profile
  • Bank details changed shortly before a large payment
Nothing on this rail has a fixed position. The events below can fire in any sequence, several at once, or never, which is exactly why a review calendar cannot be the mechanism that catches them.

A review calendar assumes change accumulates at a predictable rate. It does not. A customer can be unchanged for six years and then acquire a new ultimate owner, a new jurisdiction and a press mention in the same fortnight.

Triggers arrive without order, sometimes several at once, and often not at all. Nothing on the rail above has a fixed position, which is the point: a mechanism that fires on dates cannot catch events that ignore them.

The interval that decides everything

The largest span on the rail is not the review. It is the gap between a change happening and your firm detecting it.

Nothing in the review process shortens that gap. It is set by detection sources: whether you watch ownership registries, whether media monitoring covers the right languages and thresholds, whether jurisdiction status changes reach your system automatically. A firm with excellent review procedures and poor detection is slow in the only place that matters.

Why change of control leads the list

It alters who is actually behind the customer, and it is the change least likely to be volunteered. Ownership moves in registries and filings. A customer whose ultimate beneficial owner changed last quarter presents a materially different risk from the one you assessed, while appearing identical in your own records.

Everything else on the trigger list is either observable in the customer's behaviour or announced by a public authority. This one is neither, unless you are looking for it.

Materiality is what makes the model affordable

Detection without an assessment step produces a queue of reopened files nobody has capacity to work properly, and the usual outcome is that reviews get shallower rather than fewer.

The assessment exists to keep the population of full reviews small. Most detections should resolve there, which is not a failure of the trigger design but the reason it is sustainable.

Ratings that move need reasons

A risk rating that changes with no recorded cause cannot be distinguished later from one that changed by accident, and a rating that never changes at all is a record of a single opinion formed at onboarding.

Attaching the trigger to the rating move is what makes the history legible: not just that the customer is now high risk, but which event made them so and when.

For the operating model this sits inside, see perpetual KYC. For detection of the leading trigger, see Know Your Business. For the components, see adverse media checks and jurisdiction risk checks.

What we do.

Change of control detection

The highest-value trigger, and the one least likely to be reported to you. Ownership moves in registries and filings, not in customer notifications.

Jurisdiction watch

A customer can become higher risk without moving. The country did the moving, through a designation, a listing, or a change in FATF status.

Adverse media at a threshold

Media monitoring without a threshold produces a queue nobody works. The threshold is a risk appetite decision and belongs in the trigger design, not in the analyst's judgement each time.

Materiality before reopening

Reopening a file is expensive. The assessment step keeps the population small enough that the reviews which do happen are done properly.

Reasons attached to rating moves

A rating that changes without a recorded reason is indistinguishable from a rating that changed by accident.

Highlights.

  • Detection sources that surface change without the customer reporting it
  • Thresholds set deliberately rather than inherited from a default
  • A materiality step between detection and reopening
  • Every rating move carrying the reason that caused it

Questions

Common questions about trigger-event review.

What actually counts as a trigger event?
A change that could move the customer's risk rating. In practice that means change of ownership or control, a jurisdiction becoming sanctioned or high risk, adverse media above a threshold, a new director, trustee or signatory, behaviour outside the established profile, and payment details changing shortly before a large transaction. The specific set is a risk appetite decision.
Why is change of control the most important one?
Because it changes who is actually behind the customer, and it is the least likely to be reported to you. A customer whose ultimate owner changed last quarter presents a different risk from the one you assessed, while looking identical in your records.
How is this different from perpetual KYC?
They are the same idea at different scopes. Perpetual KYC is the operating model that replaces the periodic cycle across the whole book. This page covers the individual triggers themselves, which ones matter and what happens when one fires. Read them together if you are moving away from periodic review.
Does every trigger mean reopening the file?
No, and a programme that behaves that way fails quickly. Most detections resolve at the materiality step. Reopening is expensive, so the value of the assessment is in keeping the number of full reviews small enough that they are done properly.
What is the risk of relying on the customer to tell you?
That the changes carrying the most risk are the ones least likely to be volunteered. Detection has to come from sources that do not depend on the customer choosing to disclose.

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