Ongoing monitoring

UK MLR 2017 reg 28(11) requires you to scrutinise the business relationship on a continuous basis, not just at onboarding. Screening a client once and never looking again does not meet that. Ongoing monitoring checks enrolled individuals for sanctions, PEP status and adverse media. For companies, it checks sanctions and adverse media; PEP status applies to their owners, who need their own screening and monitoring.

Where to find it

There is no separate Monitoring page. Monitoring is a property of a client, so it lives with your clients.

On Clients:

• the Monitoring column shows which clients are watched, and whether the screening service is still answering for them
• the Monitoring filter narrows the list to Watched, Not watched, or Needs attention
• select clients and use Start monitoring to enrol them together
• a prompt above the list counts clients you have already screened who are not being monitored, which is the coverage gap that matters

On a single client: Client profile → Monitoring, which also carries that client's alert history and a PDF report for your file.

Alerts appear in the MLRO queue and on your dashboard, alongside the rest of your compliance work, rather than in a list of their own.

The old /firm/monitoring link still works and takes you to your watched clients.

How it works

When you turn monitoring on for a client, we enrol that client with the screening service as a monitored subject. From then on the service screens them every day and pushes any change back to Certivus. As a safety net in case a push is missed, Certivus also re-reads each client's latest result on a schedule your firm sets: every day unless you change it in Settings → Risk → Ongoing monitoring. Individuals are screened against sanctions, PEP and adverse media lists. Companies are screened for sanctions and adverse media. The lists cannot be switched off.

This is not a re-run of your original check on a monthly timer. It is continuous, because sanctions and PEP lists change without notice.

Why the column sometimes says something other than "Watched"

A screening service that has stopped reporting looks exactly like one that has nothing to report. Both are silence. So the column tells you which:

• Watched — confirmed within the last 48 hours. Normal.
• Awaiting first — enrolled very recently. The first safety re-check supplies the first confirmation (within a day on the default daily schedule), so this is not yet a problem.
• Stale — monitoring is on and the service has not confirmed it is watching for over 48 hours. Treat this as a gap in your coverage, not as a quiet period.
• Not armed — monitoring is switched on for the client but no subscription was ever recorded with the service. Nobody is watching them.

The Needs attention filter lists every client in the last two states, and your MLRO queue raises "Ongoing monitoring has gone quiet" on its own when any client is in one of them. That item clears itself the moment the service confirms again. There is no button to dismiss it, deliberately: silencing a coverage gap is not the same as closing one.

If screening turns up a hit it has not alerted on before, it becomes an alert and enters your MLRO queue. Each hit alerts once: once you close an alert, the same hit does not raise it again. A hit you cleared as a false positive when you reviewed the screening is not raised again: it is recorded as an alert that is already closed, with a note saying when and why it was cleared, and your client is not sent back to review. The exception is a hit that has become more serious since, for example one you cleared as a PEP match that now appears on a sanctions list. That raises a normal alert. See Reviewing possible AML matches.

Dealing with an alert

Open the client, go to Monitoring, and the alert is at the top of the tab. Your MLRO queue and dashboard link straight there.

• Escalate to MLRO — hands it to whoever makes the decision. One click; nothing is closed.
• Not this client — a false positive. You must record what you compared (date of birth, nationality, the listed entity's own detail).
• Resolve — you have decided and acted. You must record what you decided.
• Snooze — park it without closing it.

Closing an alert requires a note, deliberately. The note is the part a supervisor reads, and "someone dismissed a PEP match" without a reason is not a defensible record. Closed alerts stay on the tab with their reason, and they appear in the client's monitoring report.

Only a firm owner, a manager or the firm's MLRO (or deputy MLRO) can action an alert.

A confirmed match is not the end of it: raise an internal SAR from the client's page, and consider whether the client's risk rating should change.

What it costs, and what you are committing to

Monitoring is £1.49 per client per year, charged when you start it. It is included at no extra cost on subscription plans.

It is a 12-month term, paid up front. Enrolling ten clients pays for ten client-years on the day you start.

You can switch monitoring off for a client at any time. We then remove them from the screening service, normally within the hour, and they stop being screened. Switching it off early does not refund the rest of the term.

That is why the bulk action tells you the number and the total before you confirm, and why it skips clients who are already monitored.

Related

• Client compliance status: per-client state
• MLRO Queue: where alerts surface for action
• AML Calendar: when each client is due