Perpetual KYC (pKYC): What It Means for UK Firms
Certivus AML team8 minUpdated 2026-06-27
In brief: Perpetual KYC means keeping client due diligence current through event-driven monitoring instead of waiting for a fixed periodic review date.
Key points
- pKYC is about trigger-based review, not constant manual checking.
- Useful triggers include ownership change, sanctions updates, new matters, and unusual activity.
- The file should show what changed and how the firm responded.
What is perpetual KYC?
Perpetual KYC, or pKYC, is the idea of keeping customer due diligence current through ongoing monitoring and event-driven updates. Instead of waiting for a review date, the firm responds when client facts change.
Useful review triggers
- Ownership or control changes.
- New director, PSC, trustee, or beneficial owner.
- New high-risk matter.
- Source-of-funds concern.
- PEP, sanctions, or adverse media update.
- Client activity no longer matches the expected profile.
Practical point
Most small and mid-sized firms do not need a complex pKYC programme. They need clear review triggers, task ownership, and records that show what changed.
This guide is general information, not legal advice. Apply it through the Money Laundering Regulations 2017, supervisor guidance, and the firm's own risk-based AML procedures.