Ongoing monitoring

Keeping watch after onboarding, not just at signup.

A customer who passed every check on day one can change over time, so the business keeps looking at their activity and rechecks them against current lists.

Continuous evaluation of customer activity and screening status against expected behavior and current lists. Screening status is whether a customer currently matches any sanctions, politically exposed person, or adverse media lists.

Ongoing monitoring typically includes several activities:

• Transaction monitoring, which compares activity with what the customer was expected to do.
• Re-screening, which checks customers against updated sanctions, politically exposed person, and adverse media lists.
• Profile updates, which refresh customer information when circumstances change.
• Risk rating reviews, which adjust a customer's risk level based on what the monitoring finds.

A monitoring cycle typically works like this:

1. The institution sets an expected profile for each customer.
2. Systems watch activity and list changes continuously.
3. Unusual activity or new matches create alerts.
4. Analysts review the alerts and may escalate, file a report, or update the risk rating.

Ongoing monitoring sits next to terms that are easy to mix up:

• Perpetual KYC (pKYC) is a way of refreshing customer records continuously, which monitoring can trigger.
• Sanctions screening is one check that runs repeatedly as part of monitoring.
• Customer due diligence (CDD) includes monitoring as one of its core elements.