KYC Risk Scoring — Tier Mapping & Perpetual KYC

§ 03Tier → due-diligence mapping

A score is only useful if it triggers an action. The mapping below is JPMorgan policy — each tier maps to a different set of evidence requirements, monitoring cadence, and approval level. ALSAFA at 78 falls in High; EDD required.

Tier-action matrix

Tier	Score band	Diligence	Approval	Refresh
Low	0 – 24	Simplified DD	RM auto	36 mo
Medium	25 – 49	Standard DD	RM + AML L1	24 mo
High	50 – 79	EDD	AML L2 + MLRO	12 mo + pKYC
Prohibited	80+	Onboarding refused	Decline / SAR	—

Within a tier, score deltas drive cadence: 78 is 1pt below "Prohibited" so ALSAFA gets the tightest High-tier cadence (90-day pKYC vs 12-month baseline).

EDD requirements triggered · ALSAFA

Full beneficial-owner identity verification at all 3 layers · passports + government-ID
Wealth-source forensic memo — signed by external counsel (verified)
Adverse-media sweep · MENA & EU press · last 5 years (clean)
Sanctions screening · OFAC, EU, UN, UK · refreshed daily
PEP enhanced screening · primary + family + close associates · 3rd-party data
Source-of-funds for initial $80M · trust deed + 2 years bank statements
Transaction-monitoring profile · custom thresholds applied
MLRO sign-off · obtained · April 14, 2026

§ 04Perpetual KYC · what changed for ALSAFA in Q2 2026

Static KYC dies the moment you sign off. pKYC continuously monitors a customer's score against external events and transactional patterns. In one quarter, ALSAFA's score moved on three of four dimensions — each change triggered automated re-scoring.

pKYC event log · Apr–Jun 2026

Date	Event	Dimension	Δ score	Action
Apr 14	Onboarding · baseline	All	+78	Approved EDD
Apr 27	Adverse-media hit (resolved false positive)	Customer	+4	Investigation closed
May 09	First wire · $42M from Geneva fiduciary	Product	−2	Consistent with profile
May 22	UBO appointed to advisory board · holding co.	Customer	+6	Re-screen PEP
Jun 03	Outbound wire · $8M · Cayman SPV (new beneficiary)	Product / Geo	+9	Hold · investigate
Jun 07	SPV verified · pre-existing family vehicle · released	Product / Geo	−5	Cleared
Jun 18	FATF grey-list update · MENA jurisdiction added	Geography	+8	Re-score all customers
Jul 01	Current composite	—	83	Re-tier review

Why pKYC matters — the regulatory shift

Static annual KYC was the standard for 25 years. The FATF 2023 update and the EU AML Authority's 2025 push made continuous monitoring the expected baseline for High-tier customers.

For ALSAFA, the FATF grey-list update on Jun 18 pushed the composite from 78 to 83 — into Prohibited territory. Without pKYC this would not have been visible until the next annual review.

Disposition Re-tier review opened Jul 01. Two paths: (i) downgrade composite via additional EDD evidence & reverse-tier to High, or (ii) exit relationship. MLRO decision pending.