Shadow KYC · Fund administrator KYC testing
Your board now needs its own evidence that your administrator's investor files meet your fund's AML policy. Shadow KYC gives you that evidence without hiring a team or reviewing a single file yourself: send us 25 files, get a board-ready gap report.
Redacted files accepted · Gap report in days · Fixed price agreed before we start
CIMA's AML Rule took effect on 18 September 2026 · What changed
Firms we've worked with
shadow KYC · noun
An independent, parallel review of the investor KYC files a fund administrator keeps. We test each file against the fund's own AML policy, and the fund's board owns the evidence.
Compare shadow NAVThe 25-file test
We agree a risk-weighted selection: PEPs and high-risk investors first, then recent onboardings and a random draw. One file includes the investor’s full ownership chain.
Findings cover the files tested, not the whole investor population. We recommend whether to extend the review and when to re-test.
Test 25 files before your auditFixed quote within one business day of scoping. Report usually in days after file release; complex structures and exceptions affect timing.
Sample report
Category totals for the board. Evidence and next actions for the administrator.
Shadow KYC · Q4 2026
25 files tested · 11 with exceptions
| Category | Gaps | Rate | Oldest |
|---|---|---|---|
| Identity and verification | 1 | 4% | 212 days |
| Beneficial ownership | 3 | 12% | 340 days |
| Source of funds and wealth | 2 | 8% | 188 days |
| Screening | 0 | 0% | None |
| Risk rating | 2 | 8% | 263 days |
| Periodic refresh | 5 | 20% | 402 days |
| Maker-checker | 1 | 4% | 96 days |
| Record retention | 0 | 0% | None |
Illustrative report for a fictional fund.
The evidence behind the number
Scope
A specialist reviews every exception. High-risk and complex files get senior review. Policy gaps go to your board.
Valid documents and required certification.
Evidence for each link, to your threshold.
Documented where the risk rating requires it.
Correct lists, hit dispositions and re-screening.
A recorded rating with supporting rationale.
Review dates met; overdue files aged.
Second-person review before approval.
Retrievable for at least five years after exit (s.10.6.1).
CIMA AML Rule
Since 18 September 2026, CIMA-registered mutual and private funds must meet the Rule’s requirements. Your fund retains ultimate responsibility when relying on its administrator (s.5.3).
Provide timely and sufficient evidence of compliance on request.
CIMA AML RuleMonitor outsourced work and test it at set intervals.
CIMA FAQsA provider-level review alone does not give sufficient fund-specific audit assurance.
CIMA FAQsRead the CIMA AML Rule guide · EU AML Regulation, Article 18
Jordan Chung’s work at KPMG Forensic included KYC remediation at JP Morgan Asset Management.
Meet the teamAccess, confidentiality and transfer terms agreed before any file moves.
Trust centreShadow KYC · FAQ
Scope, oversight and the limits of a sample.
Test 25 files before your auditShadow KYC independently tests your fund administrator’s investor KYC files against your AML policy. Your board gets an evidence-linked gap report. Like shadow NAV, it gives the fund an independent check on its delegate’s work.
A risk-weighted sample gives an initial view of file quality and helps target further testing. It supports conclusions only about those files, not the full population. Your board decides the appropriate oversight arrangements.
No. Section 12 requires a separate audit of the whole compliance programme. Shadow KYC supplies ongoing file-testing evidence; your auditor determines the audit scope, procedures and conclusions.
Your board requests access under the administrator’s engagement. We accept redacted copies where tests remain possible, and specify required fields, such as names for screening, before redaction. Data terms are agreed before transfer. AgentKYZ is SOC 2 Type II.
We confirm a fixed quote within one business day of scoping. Pricing depends mainly on ownership complexity. The report usually follows within days of file release, depending on the exceptions needing review.
From 10 July 2027, Article 18 of Regulation (EU) 2024/1624 keeps obliged entities liable for outsourced tasks. Shadow KYC provides file-level oversight evidence. Take legal advice on which entity in your structure is obliged.
It binds Cayman funds and CIMA-registered managers. SFC or MAS licensing alone does not bring a manager into direct scope, but its Cayman fund retains the oversight duty. Take legal advice on your structure.
Yes. Administrators can run KYC reviews in our software and arrange independent Shadow KYC testing for client funds. The fund’s board determines its oversight arrangements.
Start with 25 files
A 15-minute scoping call. A fixed quote within one business day. No investor files needed for the call.
Need help fixing the gaps? Cayman Islands managed KYC · KYC software for your own team
Shadow KYC is provided by AgentKYZ, operated by Cortexa Research Lab Limited. General information, not legal advice. CIMA references are to the AML Rule in force from 18 September 2026 and its AML/CFT FAQs. The EU AML Regulation applies from 10 July 2027.