Ongoing Monitoring

Ongoing monitoring is the continuous process of reviewing customer relationships after onboarding to detect changes in risk profile, ownership, or suspicious activity.

Two Types of Monitoring

Transaction Monitoring

Reviewing customer transactions for:

• Unusual patterns
• Threshold triggers
• Deviation from expected behavior
• SAR-worthy activity

Relationship Monitoring

Reviewing customer information for:

• Ownership changes
• Business model changes
• Regulatory status changes
• Adverse media events

Monitoring Triggers

Time-based: Annual review, risk-based frequency

Event-based: Ownership change, new PEP hit, sanctions match

Transaction-based: Unusual activity, threshold breach

External: Regulatory alert, news event

Refresh Frequency

High risk: Annual or more frequent

Medium risk: Every 2-3 years

Low risk: Every 3-5 years

Ongoing Monitoring and KYB

For KYB, ongoing monitoring includes:

• Re-screening beneficial owners against sanctions and PEP lists
• Checking business registry for status changes
• Monitoring for adverse media
• Reviewing transaction patterns against expected activity

Without ongoing monitoring, customer knowledge becomes stale and risk assessments unreliable.

---

Related: Adverse Media | Watchlist Screening | CDD