Ongoing Monitoring in AML: Practical Guide
In brief: Ongoing monitoring means keeping the client risk picture current during the relationship, not leaving CDD untouched after onboarding.
Key points
- Ongoing monitoring should be risk-based.
- Useful triggers include ownership changes, new services, unusual activity, sanctions or PEP updates, and stale evidence.
- Record what changed and how the firm responded.
What is ongoing monitoring in AML?
Ongoing monitoring is the process of checking whether the client's activity, ownership, risk, and evidence still match the decision the firm made at onboarding. It does not require constant manual checking of every file. It does require a defensible way to notice important changes.
Useful review triggers
- Client changes name, structure, directors, PSCs, trustees, or controllers.
- New service or matter is higher risk than the original work.
- Source of funds does not fit the client's profile.
- Screening produces a new PEP, sanctions, or adverse media result.
- Documents expire or become stale.
- Staff notice facts that contradict the risk assessment.
Practical record
A good monitoring note says what changed, what was checked, who reviewed it, and whether the risk rating or acceptance decision changed.
This guide is general information, not legal advice. Check MLR 2017 Regulation 28, GOV.UK's money laundering supervision responsibilities, HMRC's CDD testing guidance, and your supervisor's current sector guidance before making a compliance decision.