Ongoing monitoring
Ongoing monitoring is the continuous obligation to scrutinise transactions and client activity throughout a business relationship and to keep CDD records up to date. It requires watching for transactions or behaviour that is inconsistent with the stated purpose of the relationship or the expected risk profile.
ongoing monitoring does not require daily scrutiny of every client. It means having a schedule for reviewing client files based on risk level, and updating records whenever circumstances change — such as changes in ownership, new services, or unusual financial activity.
Other terms that go with Ongoing monitoring
In AML, risk assessment operates at two levels. A firm-wide risk assessment identifies the overall money laundering risks facing a practice — covering client types, services offered, geographies, delivery channels, and funding sources. A client risk assessment scores an individual client as low, medium, or high risk and determines what level of due diligence to apply.
Sanctions screening is the process of checking clients, their beneficial owners, and associated parties against official sanctions lists maintained by bodies such as the UK Office of Financial Sanctions Implementation (OFSI), the United Nations Security Council, the European Union, and the US Office of Foreign Assets Control (OFAC). Acting for a sanctioned individual or entity is a criminal offence.
Record keeping is the legal obligation under MLR 2017 to retain CDD evidence, risk assessments, screening results, transaction records, policies, training records, and suspicious activity decision logs for a minimum of five years after the client relationship ends. Records must be retrievable and suitable for inspection.
Put Ongoing monitoring into practice with Certivus
Knowing the term is the first step. Certivus gives you the workflows — client intake, CDD, EDD, PEP and sanctions screening, audit-ready records — to apply it across every client.
Back to the full glossary