According to a reputable financial news source, a client is being taken over by one of its competitors. The public registry has not yet reflected the ownership change. Which step should the KYC analyst take?

A report from a reputable financial news source about a significant change, such as a corporate takeover, constitutes an event trigger for a Know Your Customer (KYC) review. While the news article is not sufficient evidence on its own to update a client's profile, it obligates the analyst to take proactive steps to verify the information. The most reliable and direct method of verification is to obtain primary source legal documents from the client, such as a merger agreement or an updated share register. This approach ensures that the client's records are updated based on official, verifiable documentation, even if public registries have not yet been updated.

B. Updating a client's profile based solely on a news source, even a reputable one, is non-compliant. News articles are not primary legal evidence and can be incomplete or inaccurate.
C. Putting the refresh on hold is a passive approach that neglects the analyst's duty to maintain accurate and up-to-date client information, thereby increasing potential risk.
D. This option implies inaction. While the public registry is a key verification source, it may not be the most current. The analyst must proactively seek to confirm the change using other reliable means.

1. ACAMS CKYCA Study Guide (2nd Edition). Chapter 4: Conducting Customer Due Diligence (CDD). The guide emphasizes that when an event-driven review is triggered (e.g., by adverse media or news of a merger), the financial institution must take steps to verify the change in the customer's profile, including ownership and control structure, by obtaining reliable, independent source documents. Relying on unverified media reports or passively waiting for public records to update is contrary to a risk-based approach.

2. Financial Action Task Force (FATF). (2023). Guidance on Beneficial Ownership (Recommendation 24). Paris: FATF/OECD. This guidance underscores the importance of using a range of sources to verify beneficial ownership information. It states that financial institutions should take reasonable measures to verify the identity of the beneficial owner using "reliable, independent source documents, data or information" (Interpretive Note to Recommendation 10). A news report would trigger the need to seek such documents.

3. Wolfsberg Group. (2017). Frequently Asked Questions (FAQs) on Correspondent Banking. The principles outlined, while specific to correspondent banking, stress the importance of event-driven reviews in response to material changes in a client's circumstances, including changes in ownership. The expectation is to gather and verify documentation to substantiate such changes. (See FAQ 45 on Periodic and Event-Driven Reviews).