CXC Poll & Report on KYC & AML in corporate treasury

The new CompleXCountries (CXC) report: Corporate Treasury - Approaches & Experiences with KYC & AML has now been published.

The report, based on a detailed peer group discussion between treasurers from global MNCs based in Europe and the United States was a deep dive into the current challenges treasurers face in complying with banks' requirements for KYC and AML information and how they are handling them. There is clearly a lot more than banks could be doing to take unnecessary friction out of this process.

The peer discussion followed up on a simple LinkedIn poll which showed that, if anything KYC and AML compliance in 2025 was (even) worse than 2024 - only 23 % saying it's getting better compared to 5% saying it's getting worse.

Issues raised in the discussion included:

  • Repetitive and inefficient KYC and AML data collection
  • Increasing volume and scope of data requests
  • Lack of consistency across banks
  • Failure to adhere to agreed KYC schedules
  • Surprise mid-year KYC data requests
  • Duplicate and inconsistent data requests across bank entities and jurisdictions
  • Requirement for hard-copy documents and document loss
  • Different KYC renewal frequencies within the same banking group
  • Banks citing legal or regulatory requirements without evidence
  • Banks not understanding their own KYC requirements
  • KYC departments in banks operating in silos and not leveraging relationship knowledge
  • Requests about activities in countries unrelated to the banking relationship
  • Increased scrutiny of internal controls
  • Lowering of UBO reporting thresholds
  • Expansion of sanctions questionnaires beyond sanctioned countries.
  • Some banks such as JP Morgan and BNP Paribas were singled out as making the greatest effort to make life for their clients easier.

Banks discussed in the report included: HSBC, BNP Paribas, Bank of America, JP Morgan & Citi.

Read the report here https://www.complexcountries.com/corporate-treasury-approaches-experienc...

 

 

Date posted: 
Tuesday, 13 January 2026