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
| Trigger Type | Examples |
|---|---|
| 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
| Risk Level | Typical Refresh Cycle |
|---|---|
| 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