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.