Define your re-verification triggers in your AML/KYC policy: calendar-based (e.g., every 1, 2, or 3 years based on customer risk tier), event-based (change of address, large transaction threshold, sanctions list hit), and ongoing monitoring alerts.
Build a scheduled job (cron or task queue) that queries your customer database for users whose last verification date exceeds the policy threshold for their risk tier, and enqueues them for re-verification.
For each queued customer, call your IDV vendor's API to initiate a new verification session pre-populated with the customer's existing data; send the customer a notification with a link or in-app prompt to complete the re-verification.
Track completion status and implement escalation logic: if a customer does not complete re-verification within a grace period, restrict their account access in accordance with your policy until re-verification is complete.
On completion of re-verification, update the customer record with the new verification status, timestamp, and vendor transaction ID; re-run watchlist screening as part of the periodic review.
Produce periodic review reports for your compliance team showing re-verification rates, overdue reviews, and outcomes; retain all re-verification records for the regulatory minimum retention period.
Known gotchas
Regulatory requirements for re-verification frequency vary by jurisdiction and customer risk tier; do not apply a single flat re-verification interval to all customers without a risk-based rationale.
Account restriction logic for non-compliant customers must be implemented carefully to avoid violating consumer protection laws (e.g., improperly freezing accounts); involve legal counsel in defining the grace period and restriction policy.
Re-verification flows that reuse stale IDV sessions or skip liveness checks are compliance gaps; ensure periodic reviews are substantive re-checks, not just record refreshes.
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