Ongoing monitoring

Continuous review of a business relationship and updating of client data throughout its duration.

In practice

Ongoing monitoring combines three elements: periodic reviews based on the risk category, event-driven reviews – for example after a move, a change of control or a screening hit – and the monitoring of transactions against the expected profile. In practice, review dates are kept in a compliance calendar, and each review ends with a dated result: information confirmed, updated or escalated.

Distinctions and common mistakes

Ongoing monitoring is more than re-running a screening. A common mistake is review dates that are set at onboarding but never followed, so that high-risk relationships go for years without a documented review.

Related terms

KYC

All the checks with which an institution identifies its clients, establishes their beneficial owners and assesses the risk of the relationship.

Risk-based approach

Principle under which the scope and depth of due diligence depend on the specific money-laundering risk.

Mentioned in these guides

• Due diligence obligations under the Swiss Anti-Money Laundering ActDue diligence under the Swiss AMLA: identifying the contracting party, establishing the beneficial owner, special clarifications, records – and practice.
• The KYC process in a family office: from onboarding to periodic reviewThe full KYC process in a family office: pre-screening, identification, risk rating, approval, ongoing monitoring, event reviews, periodic review and exit.
• Building the risk profile of a business relationshipStep by step to a robust risk profile: business profile, risk factors, weighting, reasoning and the triggers for a reassessment in a family office.
• The KYC file: structure, contents, auditabilityHow an audit-proof KYC file is structured in a family office: outline, mandatory contents, keeping it current, retention periods and typical audit gaps.
• Transaction monitoring in a family officeHow a family office monitors transactions in line with risk: criteria for anomalies, clarification, documentation and the link to the reporting obligation.
• Operational due diligence: reviewing asset managers and fundsHow family offices review asset managers and funds operationally: custody, valuation, governance, fees, IT, compliance, red flags and a questionnaire.
• The investment process in a family office: from idea to monitoringHow a family office structures investment decisions: pre-screening, due diligence, investment memo, decision, limits, monitoring and exit.