Split the onboarding rota by customer type. Retail holds are many and quick: a document that does not match, an address that will not verify. Corporate holds are fewer and slower: ownership chains, nominee directors, source of wealth. Staff each line with analysts trained for it.
Add a second reviewer for every high-risk approval, and plan for the surge after each product launch. Onboarding is the first experience a customer has of the organisation; a rota that leaves them waiting a week for a decision on a mismatched postcode costs customers before they have started.
What does the onboarding rota cover?
An onboarding agent collects documents, checks identity, screens names, verifies addresses and companies against registries, and drafts the risk rating. Within its bounds it approves clear, low-risk retail customers. It holds the rest: mismatches, screening hits, companies whose beneficial owners it cannot identify, high-risk ratings, and source-of-funds explanations that need judgement. Each held applicant is a customer waiting to open an account.
The head of onboarding owns the rota. The MLRO's team sets which approvals need a second reviewer. The guide to AI agent skills by role covers what KYC analysts need to know, and what a reviewer rota is explains the term.
What are the steps?
- Agent, depth 1: reports holds by customer type, reason and age.
- Person (head of onboarding): sets response targets per line. Retail holds within hours, because applicants abandon; corporate holds within days, because the work is deeper; high-risk second reviews within one working day of the first decision.
- Person (head of onboarding): staffs the retail line by the hour. Applications cluster in evenings and after marketing pushes; the agent's history shows when.
- Person (head of onboarding): staffs the corporate line by the day. Analysts trained in ownership structures, with an enhanced due diligence specialist available.
- Agent, depth 3: approves clear low-risk retail applicants. Within bounds certified on the organisation's own cases.
- Agent, depth 2: drafts the case for each hold. Documents, screening results, registry extracts, and the provenance of each fact.
- Person (analyst): decides each held applicant. Approve, request more, decline, or escalate.
- Person (second reviewer): checks every high-risk approval. Named on the rota, different from the first analyst.
| Step | The agent does | Depth | Stays with a person |
|---|---|---|---|
| Retail low risk | Approves within bounds | 3 | Daily sampling |
| Retail mismatches | Holds with the mismatch explained | 2 | Analyst decision |
| Screening hits | Holds; does not discount alone | 2 | Analyst decision, escalation if possible match |
| Corporate ownership | Drafts structure from registry data | 2 | Analyst identifies beneficial owners |
| High-risk approval | Holds | 2 | Analyst decides; second reviewer checks |
| Account opening | Opens after approval | 3 | The approval that permits it |
How should the two lines be staffed?
Retail and corporate KYC use different skills and run at different speeds. Mixing them in one queue means corporate cases are picked up by whoever is free, who may not know how to trace a holding company through three jurisdictions, and retail applicants wait behind a single complex case.
Give each line its own named analysts each day. Cross-train in quiet periods so either line can borrow in a surge, but only people who have shown they can handle the other line's holds. A reviewer onboarding checklist for the onboarding team sets what a new analyst must complete before joining each line.
Which controls matter, and what evidence do they leave?
- High-risk approvals have two names. Evidence: first analyst and second reviewer on the verdict.
- Screening hits are decided by people. Evidence: the analyst's name and reason on each discounted or escalated hit.
- Ownership is evidenced. A registry extract is signed by the registry; an ownership chart the customer supplied is declared. Evidence: provenance on each owner identified.
- The agent's retail approvals are sampled. Evidence: a daily sample checked by a named analyst.
- Lines are staffed separately. Evidence: the rota shows retail and corporate analysts for each day.
What should be measured?
- Time from application to decision, per line, against target.
- Applicants abandoning while held.
- High-risk second reviews completed within target.
- Agent retail approvals found wrong in sampling; any finding triggers a review of its bounds.
- Corporate cases waiting for an enhanced due diligence specialist.
Where does it usually go wrong?
Launch surges. A new product or campaign multiplies applications. Holds rise in proportion, and the retail line is overwhelmed within days. Plan with the product team.
Second review becomes a bottleneck. If only senior analysts can second-review, high-risk customers wait longest. Train more second reviewers.
Handover between lines is lost. A retail applicant who turns out to own a company, or a corporate case whose director needs personal KYC, crosses lines. Name who owns crossover cases, or they sit in both queues and neither.
Speed pressure on screening. Under a retail clock, analysts discount screening hits faster than they should. Sample discounts weekly.
Credit and risk teams staff their queues with different rhythms; compare the rotas for the credit team and the risk team.
Questions people ask
Should the agent approve any corporate customers on its own?
Most organisations keep every corporate approval with a person, because ownership analysis needs judgement. If you extend the agent's bounds, certify the capability on your own corporate cases first.
How large should the corporate line be?
Large enough that corporate cases are decided within target without borrowing retail analysts in a normal week. Work it out from the agent's history of corporate holds and the time each takes.
What happens to an applicant whose high-risk approval is rejected at second review?
The second reviewer records why, and the case returns to the first analyst or goes to the enhanced due diligence specialist. The applicant is told there is a delay, without revealing the reason where that could tip off.