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Onboarding

KYC & Customer Onboarding

The onboarding pipeline from first contact to approved, risk-rated and monitored customer — including KYB, ultimate beneficial ownership and the checkpoints that must not be skipped under pressure to convert.

Typical duration
6–10 weeks to redesign
Applies to
Banks, PSPs, NBFIs
Legal basis
AML Law 80/2002 & CBE rules
Output
CDD/EDD workflow & risk model
0Stages from contact to monitoring
0% typical ownership threshold for UBO identification
0Risk tiers driving due diligence depth

The onboarding pipeline

Each stage has a decision gate. A customer who fails a gate does not move forward — commercial pressure to override that is the single most common root cause of onboarding findings.

01

Identification

Collect and verify identity. For individuals: National ID or passport. For entities: commercial register, tax card, articles of association.

Verified identity record
02

Beneficial ownership

Trace ownership through every layer until a natural person is identified. Document the chain, not just the endpoint.

UBO chain document
03

Screening

Screen against sanctions, PEP and adverse media lists. For Arabic names, transliteration-aware matching is essential or true hits are missed.

Screening result & disposition
04

Risk rating

Score the customer against the model derived from your enterprise risk assessment. The rating determines due diligence depth and review frequency.

Assigned risk tier
05

CDD or EDD

Standard due diligence for low and medium risk. Enhanced due diligence with source of funds and senior approval for high risk and PEPs.

CDD/EDD file
06

Approve & monitor

Approve at the right authority level, then place the customer under ongoing monitoring calibrated to their risk tier.

Monitoring profile

Risk tiers and what they trigger

The rating is not a label. It determines how much evidence you must hold and how often you must revisit it.

Low risk

Simplified due diligence

Standard identification and verification. Periodic review on a longer cycle.

  • Review every 3 years
  • Standard monitoring
Medium risk

Standard due diligence

Full CDD with purpose and intended nature of the relationship documented.

  • Review every 2 years
  • Threshold alerts
High risk / PEP

Enhanced due diligence

Source of funds and source of wealth evidenced, senior management approval before onboarding, and enhanced ongoing monitoring.

  • Annual review
  • Senior sign-off
  • Enhanced monitoring

The checkpoints that fail inspections

Every one of these has been a real finding in the Egyptian market.

Need this assessed for your organisation?

Every engagement is led by a senior practitioner and closes with documented, regulator-ready evidence of what was built.

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