What is Ongoing Monitoring?

Ongoing monitoring involves considering whether:

• the matter remains consistent with your understanding of the client;
• the client remains consistent with the information obtained during onboarding;
• ownership and control arrangements remain unchanged;
• the source of funds remains consistent with previous explanations;
• the purpose and nature of the matter remain unchanged;
• new parties have become involved;
• new jurisdictions have become involved; and
• any new financial crime risks have emerged.

The key question is often: "If this matter were presented to me for the first time today, would my understanding and risk assessment remain the same?"

If the answer is no, further consideration may be required.