For many SME focussed banks, KYC investments have streamlined the onboarding journey but legacy KYC records – the back-book – often remain dormant until a regulatory inspection, or an enforcement case at a peer institution, forces a wholesale review. The challenge that follows is how to remediate at scale, with urgency, and without the need to deploy a large team of experts.
This tension is the context for London based corporate digital identity (CDI) and KYC automation specialist, Encompass’ launch of EC Review in response to clients articulating this persistent challenge. The company frames EC Review as a repeatable service model designed to relieve pressure on stretched operations and give risk teams confidence and control over their entire client book – not just the latest onboarded cohort.Addressing Back-Book Risk
The problem EC Review is designed to solve is an old one, but until recently it has been managed largely through brute force: consultant-led remediation projects, large internal review squads and ad-hoc refresh programmes triggered by perceived risk. What has changed is scale – and urgency.
Howard Wimpory, KYC Transformation Director at Encompass explained to RegTech Insight that client feedback sparked the idea. “The need emerged from conversations with clients who said: I’ve got a population of client records I’m concerned about,” he says.
That concern is grounded in a familiar fact of life for AML compliance leaders: review cycles are only as robust as the processes that enforce them. High-risk clients may be refreshed annually, medium-risk every three years, low-risk every five. But between cycle points, structural shifts in ownership, changes in control, and emergent vulnerabilities can go unnoticed.Catalysts for Remediation
Enforcement actions – and the sector-wide peer reviews they often trigger – have become a catalyst. “When a UK bank was fined over money laundering through a pawnbroker client,” says Wimpory, “every bank in the UK immediately reviewed its exposure to clients across the pawnbroker segment.”
At its core, EC Review is designed for scale. Rather than approaching legacy remediation as a case-by-case exercise, banks define a population of records – often in the thousands – specify the attributes to be refreshed and move the entire cohort through a structured review cycle in a controlled batch.
“They will identify the data attributes they need screened from trusted sources and provide us with a file… perhaps 10,000 at a time,” Wimpory explains. “We conduct the data searches and return the output – sometimes as simple as a structured spreadsheet.”
The result is not a one-off investigation, but a repeatable, high-volume process that allows institutions to address back-book risk without diverting disproportionate internal resources.
Low-Touch Deployment
The key attribute for client firms is the “low touch” model. EC Review does not require full integration with a bank’s case management system or a complete platform rollout. It can operate off-platform, enabling rapid onboarding into an urgent project without the overhead that typically accompanies urgent response.
The foundation for EC Review rests on Encompass’ core platform, EC360. The company has long focused on one problem: how to turn messy, jurisdictionally fragmented public corporate data into structured, reusable going-in information. “Imagine all the data available in the public domain across the globe that banks access to build a bona fide profile of a client – that’s what we provide,” Wimpory says.
By normalising more than 200 global public sources through a common schema, capturing ownership structures and evidential documentation with provenance, and making it accessible via API or UI, Encompass positions itself as the structured data layer that sits above registries and beneath a bank’s CLM and risk systems. EC Review taps into that same engine extending Encompass’ core onboarding and Corporate Digital Identity capabilities into structured, high-volume remediation and refresh programmes.
Calibrated Perpetual KYC
The same architecture underpins Encompass’ perpetual KYC (pKYC) capability, which mitigates against missing a material event between periodic reviews. But the full value of pKYC comes with an operational challenge – always-on review is only sustainable if it is calibrated. “If they monitor 100 data attributes… there are probably fewer than a dozen that materially affect the risk calculation. So, monitor those,” he says. The emphasis is on detecting meaningful shifts – in ownership, control or jurisdictional exposure – while suppressing immaterial changes before they reach human review.
Encompass is also expanding its footprint with a digital vault solution for large multi-banked corporates. These large global enterprises often face redundant -KYC questionnaires across their provider ecosystem. Providing a centralised repository of credentials that can be shared with multiple financial institutions, insurers or legal counterparts mitigates a significant administrative overhead.
In Conclusion
Encompass CEO Wayne Johnson frames EC Review succinctly in the February launch statement: “This is not just about efficiency. It is about giving financial institutions confidence and control over their entire client book. We are helping our clients reduce hidden risk, improve client experience, and move from reactive compliance to proactive data governance.”
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