A KYC analyst handles a held action by reading the hold reason first, then checking the evidence the agent relied on, the provenance of each document and the risk rating it proposed. The analyst then approves, edits or declines the draft, and records a reason a second-line reviewer could follow a year later without asking.
Why does an agent hold a KYC action?
A held action is one the agent has drafted but may not complete itself. Every action meets five bounds at once: the agent's role scope, its certificate, its sources, the firm's own limits and the platform guardrails. The lowest one wins, and the verdict names which bound decided. That name tells the analyst where to look.
Typical KYC holds:
- A screening hit the agent may not clear, such as a possible sanctions or politically exposed person match.
- A document that arrived as an email attachment or customer upload, so its provenance is external or declared rather than signed by an issuer.
- A beneficial ownership chain the agent could not complete from a registry.
- A proposed high risk rating, which the firm's limits route to a person.
- A customer in a jurisdiction or sector the firm treats as higher risk.
What should the analyst check before deciding?
Four checks, in this order.
- The hold reason. A hold on the firm's limits (a high rating) needs a different check from a hold on sources (an unverified document).
- The evidence and its provenance. For each fact in the draft, see where it came from. A registry extract is stronger than a certificate of incorporation the customer emailed; a passport verified by an identity service is stronger than a photo of one.
- The screening disposition. If there is a hit, compare the identifiers the agent matched on: full name, date of birth, nationality, known associates. Discounting a match is a decision only a person makes.
- The proposed outcome. Does the risk rating follow from the facts, and does the due diligence level match that rating under your policy?
Approve, edit or decline: what does each mean?
| Decision | When to use it | What the reason should say |
|---|---|---|
| Approve | The draft is right as it stands | Which evidence settled the hold reason |
| Edit | The outcome is right but a detail is wrong, such as the rating, a missing document request or the next review date | What changed and why |
| Decline | The draft should not go ahead: more evidence is needed, the case goes to the financial crime team, or the relationship should be refused | What is missing or what triggered escalation |
"Checked, fine" tells nobody anything. "PEP match discounted: date of birth and nationality differ from the listed person; registry confirms director's identity" can be followed by an auditor.
Edits matter for a second reason: they are the corrections that teach the agent. If analysts keep raising the same rating for the same customer type, the pattern belongs in the agent's brief or the firm's limits, not in another hundred edits.
What does this look like in practice?
Take a payments firm onboarding a small import business. The agent gathers the registry extract, screens both directors, verifies the lead director's passport through the identity service and drafts an approval with a medium risk rating. It holds the action because the second director returns a possible match on a politically exposed persons list.
The analyst opens the hold. The listed person shares the director's name but is twenty years older and of a different nationality, and the registry extract gives the director's date of birth. The analyst discounts the match, edits the review date to the firm's standard medium-risk cycle, approves, and writes the reason. The decision, the draft and the sources are filed together in the record.
Had the match held up, the analyst would have declined the draft and passed the case to the financial crime team. The agent cannot clear that kind of hit at any depth.
What controls keep this safe?
- The agent cannot clear its own holds. Only a named person can, and their name is filed with the decision.
- Authority matches the hold. A junior analyst may handle document holds; screening hits on high-risk customers may need a senior analyst or a second approver.
- Sampling of approvals. A team lead reviews a sample of approved holds each week to catch rubber-stamping.
Neighbouring roles follow the same pattern with different evidence: see how credit analysts handle held actions and how fraud analysts handle them. For the wider skill set, see AI agent skills by role.
Where the Academy fits
Pryme Intelligence Academy's Operator track covers human review and reading the workspace, with module tests set in the learner's own industry and role, so a KYC analyst practises on onboarding holds rather than generic examples. Certified Pryme Operator requires a two-week practicum of real review decisions with no missed red line, signed off by a Pryme assessor. A firm can make the right to approve high-risk holds depend on a current certificate.
Questions people ask
Should the analyst rerun the agent's screening?
Not by default. Check the identifiers it matched on and the list date; rerun only if either is out of date.
What if the customer is waiting for an answer?
A hold never turns into an approval because time has passed. Set a response target for each hold reason and staff the queue to meet it, so speed comes from cover rather than from shortcuts.
Does approving holds raise the agent's depth?
No. Depth is earned from evidence in certification, not from individual approvals. Your edits and reasons can still improve the agent's brief, which shows up at the next certification run.