Beyond the First Check: How AMLR Extends KYC Across the Customer Lifecycle

Shufti August 20, 2026 12 minute read

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The AMLR Compliance Challenge

Customer verification does not stop at sign up. AMLR treats customer knowledge as a living state; one you maintain, keep current, and can demonstrate.

Join us for a live conversation on the three shifts that decide readiness:

✓Continuous CDD
✓Existing customer files
✓Vendor chain behind your KYC

Can you show your files are current?

Why does this matter?

Verification no longer ends at signup

Point-in-time verification is still necessary but no longer sufficient. AMLR pushes ongoing monitoring and behavioural signals to the centre of CDD, so re-checks are triggered by events and risk.

Most firms sit somewhere on the ladder between periodic review and perpetual KYC. Knowing your rung and the gap to the next one is where readiness starts.

Your existing customers are in scope too

Article 26 makes it explicit: existing customer files must be brought up to the new requirements, risk-based, high-risk first.

Everyone budgets for new-customer onboarding, almost no one budgets for the files they already hold.

You can outsource the work, not the accountability

Article 18 allows AML tasks to be outsourced, but regulatory responsibility stays with you. Every provider in your KYC chain, and every sub-provider behind them, is a dependency you must identify, oversee, and be able to explain.

Outsourcing isn't a risk. Invisibility is. The more hidden links in the chain, the harder end-to-end compliance is to prove.

MAINTAIN THE STATE. PROVE THE STATE. ONE PLATFORM OF RECORD.

Meet the Panel

Zhanel Auèzova

Lead Global Sanctions Procedures at Rabobank

Zhanel specialises in translating legislation into clear, practical bank-wide policies and procedures. Her experience spans sanctions, AML, KYC, complex investigations and global policy. One of her current focus areas is the AMLR and its implications for financial institutions - from customer due diligence to group-wide compliance and effective implementation.

Paul O’Donoghue

Senior Correspondent at AML Intelligence

Paul works as the Senior Correspondent for AML Intelligence where he leads the publication’s editorial coverage. As part of this, he provides in-depth analysis on areas including tech, finance, AML and law. He also writes the publication’s bi-weekly newsletter, as well as its weekly tech newsletter.

Raja Hassan Fayyaz

VP, Product Development & Marketing, Shufti

Raja Hassan Fayyaz is Chief Product Officer at Shufti, where he leads the teams building its identity verification, AML and fraud prevention products, working with clients including Mastercard, Stripe and Binance.

Before Shufti, he was Chief Development Officer at QuickBit, building a blockchain payment gateway handling over 20,000 transactions a month and custom crypto wallets for Bitcoin, Bitcoin Cash and Litecoin.