Performing AML checks only at onboarding leaves a dangerous gap. Clients can be added to sanctions lists, take up new political roles, or appear in negative press at any time. Without ongoing monitoring, firms risk missing crucial changes until the next scheduled review. This article explains why continuous screening is essential, what sources to include, and how to build an efficient monitoring process.
1) Why ongoing monitoring is required
International frameworks such as the FATF Recommendations and EU AML Directives emphasize that AML risk is dynamic. A client who was low risk last year may become high risk tomorrow if they are sanctioned, promoted to a senior political office, or linked to an enforcement action. Regulators increasingly expect firms to show that their due diligence is not a “one-off” exercise but an ongoing process.
2) Events that monitoring helps detect
- Sanctions changes: A client or counterparty may be newly listed by UN, EU, US, or UK authorities.
- PEP role changes: An individual may assume or leave a prominent public function, changing their risk profile:contentReference[oaicite:0]{index=0}.
- Regulatory enforcement: Firms or directors may face new fines, bans, or suspensions from supervisory bodies:contentReference[oaicite:1]{index=1}.
- Adverse media: Fresh news reports may link a client to corruption, fraud, or reputational scandals.
3) How to structure monitoring
- Frequency: High-risk clients should be monitored continuously; others may be reviewed at set intervals (e.g. quarterly or annually).
- Scope: Monitoring should cover individuals, entities, and connected parties, not just the direct client.
- Evidence: Keep a record of monitoring checks and alerts, noting the rationale for decisions taken.
4) Using adverse media intelligently
Not all news is equal. Focus on credible, verifiable sources rather than blogs or rumor sites. Prioritize adverse media categories that indicate financial crime risk, such as bribery, fraud, money laundering, tax evasion, and organized crime:contentReference[oaicite:2]{index=2}. Consider language and jurisdiction coverage: local media often reports risks before they reach international outlets.
5) Reducing “alert fatigue”
A common challenge is receiving too many irrelevant alerts. Good practice includes tuning search parameters, weighting identifiers, and dismissing low-relevance hits with a short note explaining the decision. This ensures monitoring remains actionable rather than overwhelming.
6) Building an efficient monitoring workflow
- Define a risk-based policy: which clients get continuous alerts, which get periodic reviews.
- Assign clear ownership: compliance officers should know who reviews alerts and how quickly decisions are expected.
- Document consistently: supervisors will expect to see both positive and negative results stored in files.
7) Tools that simplify monitoring
StartKYC supports firms with automated ongoing monitoring. Using Tier-1 data sources, the platform can track clients against PEP, sanctions, enforcement, and adverse media lists for 12 months at the same cost as a one-off search. Features include bulk uploads via CSV, API integration for seamless automation, and multi-user access with no extra fees. This allows compliance teams to focus on judgment, not manual data gathering.
By embedding monitoring into everyday AML practice, firms reduce regulatory risk, catch problems early, and protect their reputation. Screening should not stop after onboarding — it should continue for as long as the relationship lasts.