Ongoing Monitoring
Ongoing Monitoring refers to the obligation for regulated entities to continuously monitor transactions and the business relationship with their clients. It aims to detect suspicious activities, verify the consistency of operations with the client's profile, and keep customer information up to date.
Ongoing monitoring is an essential pillar of the AML/CTF framework that complements the initial checks carried out at the establishment of the business relationship. It comprises two main components: transaction monitoring and periodic customer file reviews. Transaction monitoring relies on automated systems that analyse operations in real time and generate alerts for atypical behaviour.
Periodic customer file reviews involve verifying that customer information remains accurate and current. The frequency of these reviews is determined by the customer's risk level: annually for high-risk clients, every two to three years for medium-risk clients, and every five years for low-risk clients. Any significant change in the risk profile should trigger an early review.
CheckFile.ai facilitates ongoing monitoring by enabling automated re-verification of identity documents during periodic reviews. The solution detects expired documents, verifies the validity of newly submitted documents, and alerts on inconsistencies between declared information and documentary data, thereby helping maintain a reliable and compliant customer file.
Regulations
Real-world examples
- 1.A bank's transaction monitoring system detects a sudden change in the volume and destination of transfers from an SME client, triggering an alert for investigation.
- 2.An insurer conducts the annual review of a high-risk client's file and discovers that their passport has expired, requiring collection of a new identity document.
- 3.An asset management firm identifies during a periodic review that a client's beneficial owner has changed without prior notification, triggering a complete risk profile reassessment.