Banks must re-check every customer. We do it, and hand back the proof.
For MLROs and heads of financial crime at payment companies and banks in Europe and the UK. We re-check your customer files; your MLRO signs. Every file comes back as a folder of evidence a regulator can open. We are looking for our first firms.
Agree what will be checked
- Customer
- SYN-00417, Specimen EMI B.V. (fictitious)
- Trigger
- Scheduled periodic review, 12 months (higher-risk segment under firm policy)
- Overdue
- 21 days at intake
- Rules
- KYC-PR-2026.2, captured before any file moved
A demonstration with a made-up customer file. The stages and the folder are real; the timings are not.
- 13 July 2026
- The Dutch central bank fines a payment company EUR 2.65 million because its customer monitoring was not working for over two years.
- 10 July 2027
- A new EU law applies: every customer's information must be checked and refreshed at least every five years, and every year for higher-risk customers.
- 2028
- A new EU authority expects to start supervising up to 40 of the largest cross-border firms directly.
- Sources
- Every date with its source
In plain words
- The rule
- By law, a bank or payment company must look again at each customer every year or every few years: are they who they said, has their business changed, is their money clean. This is called a periodic KYC review.
- The problem
- Firms have thousands of these files, not enough people to re-check them, and when the regulator asks for proof, the proof is often scattered or missing. Regulators are fining firms for exactly this.
- What we sell
- We take the files, re-check each one against the firm's own rules, and hand back a folder per file that shows what was checked, what was found and who signed. One price per closed file, agreed before any file moves; the parallel run is scoped and quoted first.
- What stays with the firm
- The decision. The firm's compliance officer, the MLRO, approves or rejects every file. We prepare and propose; we never decide for them.
What one finished file hands back
The decision
How risky the customer was rated before and after, what was decided, who proposed it, who checked it and who signed it, each with a time.
In the specimen review.json, attestations/reviewer.json, attestations/mlro.json
The evidence
Copies of the documents the decision rested on, the list of checks run against them and what each one found, all fingerprinted with a hash so a change later would show.
In the specimen sources/, review-set.json, manifest.json
The limits
What could not be completed, why, who owns it and what happens next. The folder records what was reviewed. It does not promise the customer is safe.
In the specimen review.json (open items), attestations/mlro.json (condition)
How a review cycle is designed to run
Scope
Which customers, how often, under which version of the firm's rules. Agreed in writing first.
Intake
The firm exports the files to us through an agreed route.
Re-check
A senior KYC analyst works each file against the firm's rules, with software preparing the evidence.
Second pair of eyes
A second reviewer checks the decision and the evidence.
MLRO sign-off
The firm's MLRO approves or sends the file back. We never sign for them.
Evidence folder
Each closed file leaves with its folder. A cycle report lists every file and every open item.
Software prepares. A person decides. The firm's MLRO signs.
Software gathers the documents, runs the screening and drafts the file. The analyst decides what it means. When the two disagree, the analyst's view is recorded and wins.
Why now
- 13 July 2026
- The Dutch central bank fines a payment company EUR 2.65 million because its customer monitoring was not working for over two years.
- 18 September 2026
- The European Banking Authority sets rules for how firms must manage outside providers like us.
- 5 October 2026
- The Dutch central bank fines an e-money company EUR 722,160 for not keeping up its checks on customers.
- 10 July 2027
- A new EU law applies: every customer's information must be checked and refreshed at least every five years, and every year for higher-risk customers.
- 2028
- A new EU authority expects to start supervising up to 40 of the largest cross-border firms directly.
How a firm starts
A 30-minute call
You tell us how your last round of reviews actually went. No slides.
A parallel run
You give us 100 to 300 files you have already reviewed, under a confidentiality agreement. We re-check them and hand back a folder for each.
Compare
You compare our results with your own: time per file, decisions that match, problems we found that were missed, and whether your MLRO accepts the folders.
Decide
If the folders are worth more than what you have today, we agree a price per file and start on the live backlog.
Evidence supports a decision. It does not make one. The firm's MLRO keeps the final say on every file. Nikxius is not a law firm, an auditor or a regulator. No folder promises a regulatory outcome. The service is looking for its first firms.
Tell us how your last round of reviews actually went.
Thirty minutes, no slides. Who does the re-checking today, how long it takes, and what the regulator accepted as proof. If your current setup works well, that is a useful answer too.
Talk for 30 minutesNikxius is run by Nikhil Sood, who replies to every request personally.