A KYC analyst's training plan for working with an AI agent should be built around provenance: knowing which evidence the agent relied on, where it came from, and how strong it is. The plan moves from shared vocabulary to provenance drills, shadow review, a certified practicum and sign-off. Onboarding decisions for higher-risk customers stay with the analyst.
What is this plan for?
Onboarding agents collect identity and company documents, run checks against registries and screening lists, extract data, and draft a risk rating with its reasons. Document collection and data extraction run at depth 1 or 2. Clearing standard-risk retail customers where every check passes may reach depth 3 once proven on the firm's own cases. Higher-risk customers, screening matches and anything unusual are held for an analyst. The FATF Recommendations set the international standard for customer due diligence and a risk-based approach.
Every fact reaching the agent arrives stamped with its provenance: sealed, signed, declared or external. KYC is where this matters most. A company registry extract is signed by the registry; a shareholder chart the customer drew is declared; a utility bill uploaded as an image is external. An analyst who cannot tell these apart will approve cases on evidence that would not survive a regulator's file review.
How do you fill it in?
Part A is the individual plan. Part B is a provenance drill sheet, used in week 2 and again in calibration. Analysts must classify every item correctly before moving to shadow review. Time to competence is discussed in how long it takes to train KYC analysts to supervise AI agents.
The template
Part A: individual plan
| Step | What happens | Duration | Pass condition | Signed off by |
|---|---|---|---|---|
| 1. Vocabulary | ||||
| 2. Provenance drills | ||||
| 3. Reviewer learning | ||||
| 4. Shadow review | ||||
| 5. Exam and practicum | ||||
| 6. Sign-off and rights | ||||
| 7. Renewal |
Part B: provenance drill sheet
| Evidence item | Provenance class | Enough on its own for this customer type? | What else is needed |
|---|---|---|---|
A worked example
A hypothetical business bank's onboarding team. Values are samples.
Part A
| Step | What happens | Duration | Pass condition | Signed off by |
|---|---|---|---|---|
| 1. Vocabulary | Foundations | About 4 hours | Foundations test passed | KYC team lead |
| 2. Provenance drills | Classifies 30 evidence items from past cases | One week | 28 of 30 correct; no external item treated as verified | Senior analyst |
| 3. Reviewer learning | Operator modules: how a governed agent decides, human review, keeping knowledge current | About 14 hours | Module tests set in banking onboarding | KYC team lead |
| 4. Shadow review | Decides held onboarding cases before a certified analyst releases them | Two weeks | Matches on at least 45 of 50 cases; no red line missed | Senior analyst |
| 5. Exam and practicum | Written exam; two weeks of live held cases | Two weeks | Exam at least 32 of 40; practicum at least 95 in every 100 correct, no missed red line | Pryme assessor |
| 6. Sign-off and rights | May approve standard and medium-risk business customers | One day | Head of onboarding agrees | Head of onboarding |
| 7. Renewal | Update module and short quiz | Before 12 months | Quiz passed | KYC team lead |
Part B (sample rows)
| Evidence item | Provenance class | Enough on its own? | What else is needed |
|---|---|---|---|
| Company registry extract retrieved by the agent | Signed | For existence and directors, yes | Ownership above the registry's threshold |
| Ownership chart supplied by the customer | Declared | No | Registry filings or a signed confirmation from a regulated professional |
| Director's passport photo uploaded by the customer | External | No | Identity verification through an approved check |
| Screening result from the bank's screening system | Sealed | For screening, yes | Analyst disposition of any match |
The ownership chart row is where business onboarding most often goes wrong. A customer's own chart of who owns the company is declared; the agent will hold the case if the chart cannot be matched to signed sources, and the analyst must resist approving because the chart looks professional. Applicants sometimes embed text in documents intended to influence whoever, or whatever, reads them; practise this with how to train KYC analysts to spot prompt injection and pressure. Keep decisions aligned with calibration sessions for KYC analysts, using Part B as the material.
Neighbouring plans are the training plan for fraud analysts and the training plan for credit analysts, who use the same provenance skills on different evidence. The team-wide order is in training teams for AI agents.
Questions people ask
Can the agent onboard customers without an analyst?
For standard-risk retail customers where every check passes on sealed or signed evidence, some firms allow depth 3 once the agent is certified on their own cases. Higher-risk customers stay with analysts.
What should an analyst do when sources disagree?
Hold the case and resolve the conflict with stronger evidence. The record should show which source the analyst relied on and why.
How often should provenance drills be repeated?
At every calibration cycle and whenever a new evidence type appears. New document formats are where analysts' classification slips first.