Pain Point
The meaning of KYC hasn't changed. What it takes to do it well has.
- The EU's new AML Regulation (EU) 2024/1624 applies from 10 July 2027, replacing 27 national interpretations with one directly applicable rulebook supervised in part by the new AML Authority in Frankfurt. Most firms are still running KYC policies written for the old directives.
- Regulators keep proving that weak KYC is expensive: Dutch banks ING and ABN AMRO paid €775M (2018) and €480M (2021) in AML settlements, largely over customer due diligence gaps, which is why "Netherlands KYC contract" clauses and Wwft outsourcing terms now get scrutinised line by line.
- Ownership is getting harder to see: SPVs, trusts and multi-layer holdings let a real owner sit four or five entities away from the account, and "SPV AML KYC" has become its own compliance discipline.
- The identity check itself is under attack: iProov data shows virtual camera injection attacks grew 2,665% year over year, so a document-and-selfie check that only looks for a printed photo is no longer KYC in any meaningful sense.
KYC used to mean collecting a passport copy. In 2026 it means proving, to a regulator and to yourself, that the passport, the face, the owner and the risk score all belong to the same real customer.


