In order to comply with AML (Anti-Money Laundering) regulations, you need to be constantly vigilant rather than trying to manage these processes with one-off confirmations. In these continuous efforts, Ongoing Monitoring plays an undeniably crucial role. To achieve the constant vigilance, it continuously analyzes and reviews the customer activities, risks and transactions. In this post, we will explain Ongoing Monitoring in detail.
What Is Ongoing Monitoring?
Ongoing Monitoring is one of the staples of AML processes. The importance of ongoing monitoring becomes particularly apparent when periodic KYC reviews fall short. It allows assessing risks dynamically in real-time in order to spot changes in profile, behavior or sanction changes.
How Does It Work?
First of all, there are certain triggers that activate these monitoring systems. These can be sudden profile updates or large transactions. When the system detects a red flag like these, it uses detection techniques such as risk scoring or anomaly detection to evaluate the risk. Then, additional steps must be taken, such as Enhanced Due Diligence (EDD) or Suspicious Activity Reports (SARs).
What Are the Requirements for Ongoing Monitoring?
Almost all prominent regulators in the world, such as FATF, EU AMLD, FinCEN and FCA, enforces ongoing monitoring but it is not enough by itself. You should continuously review the transactions, focus on high-risk customers, update customer information and report any suspicious activity through SARs. The main goal here, is to detect and prevent illegal activities like money laundering and terrorist financing. Let’s give an example on what could happen, when a business doesn’t adhere to these regulations. According to Reuters, Britain’s financial regulator, FCA, fined Barclays 42 million pounds due to the shortcomings in KYC (Know Your Customer) and Ongoing Monitoring.
Examples of Regulated Industries
Let’s start with banks and traditional financial institutions, who must continuously implement monitoring on transactions. Crypto Exchanges are also obligated to monitor illicit wallet use and several other processes. Even high-value goods dealers must implement proper monitoring since they handle large amounts of money. This list goes on with examples such as MSBs, real estate, gaming, gambling, law, accounting etc. In order to show how these obligations are not limited to traditional financial institutions, let’s give an example from gambling industry. According to AUSTRAC’s website, Australia’s financial authority alleged that Mount Pritchard District and Community Club group has violated the AML laws, and subsequently launched civil penalty proceedings. Among the AUSTRAC’s allegations, it is possible to see several mentions of failures in monitoring processes.
Key Triggers for Ongoing Monitoring
There are several key triggers for Ongoing monitoring such as personal data changes (address, job and ownership), large or suspicious transactions (structuring, unusual wire transfers, cash-intensive activity), negative news (alerts from trusted media sources) and sanction or PEP updates (when a customer gets listed on a sanctions list or PEP).
Ongoing Monitoring vs. Transaction Monitoring
It is not hard to confuse some aspects of these two monitoring types, so let’s list the principal differences between these. The first difference comes from their scope; Ongoing Monitoring continuously reviews the customer relationship as a whole, while Transaction Monitoring conducts real-time or batch analysis of individual transactions. Their goals also differ. Ongoing monitoring aims to ensure that customer activity is consistent with their profile but Transaction Monitoring aims to spot money laundering, terrorist financing and fraud through their transactions. Another major difference comes from their respective sources. Ongoing Monitoring takes its data from KYC, sanctions lists and media, while Transaction Monitoring’s data comes from payments and behavior of the individuals.
| Feature | Ongoing Monitoring | Transaction Monitoring |
| Scope | Customer profiles, risk updates | Transactions and payment patterns |
| Frequency | Event-triggered or periodic | Real-time or batch-based |
| Data Sources | KYC data, media, sanction updates | Transaction records, analytics |
| Purpose | Adjust risk dynamically | Detect suspicious activity |
What Is the Ongoing Monitoring Process?
If we were to summarize, it is in fact a continuous effort composed of risk segmentation, trigger detections, sanction/media data integration, generation of AI-powered alerts, thorough investigations, keeping audit trails and lastly, optimization of the systems for future risks.
How to Build an Effective Ongoing Monitoring?
We will walk you through the steps of building an effective Ongoing Monitoring. First, specify the risk tiers. These could be low, medium or high risk based on their geography, industry, transaction history and profile. Also, identify triggers that require attention. These triggers may consist of changes in ownership, negative media coverage or sanctions listings. However, these should be measurable and aligned with regulatory requirements. You can also make this process more efficient by integrating external databases like PEP lists, UBO (Ultimate Beneficial Owner) registries and sanctions lists. In this step, you can leverage necessary technology to generate real-time alerts. However, it is equally important to structure an escalation workflow to ensure rapid investigation by compliance teams. After reviewing alerts, you should readjust the customer’s risk. Throughout this process, do not neglect to maintain detailed records for future audits. After this is over, assess the alert quality and feedback loops. Lastly, make changes in rules, scoring and workflows if necessary.
When is Ongoing Monitoring Necessary?
In fact, it must stay on throughout the business relationship due to the regulations. However, there are certain cases where you must be extra careful. After the onboarding, you must apply it for any customer activity or profile shift. This is especially crucial for high-risk customers, regions and industries.
Tools and Technologies for Ongoing Monitoring
There are numerous tools that can make your job easier. For example, APIs will enable instant updates from external lists such as sanctions lists, PEPs and adverse media while supporting integration with existing systems. This real-time sync feature will not allow the risk scores to fall behind. Since we have just mentioned sanctions lists, let’s touch upon Sanction List Automation as well. With this software, systems can trigger alerts when a match is found against global sanctions, watchlists and PEP databases. Transaction Monitoring Systems also deserve a mention, since they detect unusual or suspicious transactions in real time. Several businesses offer integrated compliance suites that include numerous tools in addition to these like KYC onboarding and case management.
What Are the Challenges in Ongoing Monitoring?
One of the most common challenges you can come across during Ongoing Monitoring is the false positives overload. It is not unseen to receive several alerts due to Sanctions and PEP screening, which may lead compliance teams to spend time investigating these instead of real risks. Another scenario you could face is having difficulties when trying to integrate modern AML/KYC systems into your existing systems. Several banks and financial institutions are still relying on legacy banking systems that are not very compatible with modern solutions. This can lead to scattered information across departments, operational inefficiency and regulatory risk. Another difficulty you may face can emerge from limited third-party sources, regional restrictions or outdated data. These insufficient data can cause big gaps in risk detection, which may result in compliance failures. Last but not least, you are probably aware that AML/CFT regulations constantly change across different jurisdictions. Sanctions lists get updated daily, both global and local regulators change their expectations continuously, which can lead to penalties, license restrictions or fines. Fortunately, at Sanction Scanner we address these problems with easy API-integration, lists that are updated every 15 minutes, risk-based monitoring and several other tools.
What Are the Benefits of Strong Ongoing Monitoring
One of the most important advantages of Ongoing Monitoring is the early risk detection. An early detected risk can prevent several things such as regulatory penalties, financial crime, reputational damage and loss of trust. Also, you can get customer behavior insight through tracking evolving customer patterns over time and adjusting the risk scoring accordingly. These automated processes such as screening, scoring and alerts, will reduce the workload of your compliance teams and save money as well. Another major pro of Ongoing monitoring is that it will ensure that you are ready for future audits by maintaining full records of alerts, investigations and other necessary documents.
Best Practices of Ongoing Monitoring
We can explain these through examples across various sectors. Let’s start with banks. Like most of the financial institutions, they must continuously re-screen clients against updated PEP lists after onboarding. This is important because a customer you have onboarded can become high-risk anytime and regulators expect you to catch changes like these as soon as possible. Now, let’s continue with businesses related to crypto. Proper media screening always carries a huge importance and even more so in a dynamic field such as crypto. So, regulators such as FATF, FinCEN and EU AMLD, expect real-time risk score changes when negative news surfaces about a customer.
How Sanction Scanner Supports Ongoing Monitoring
At Sanction Scanner, we offer continuous screening of customers, counterparts and transactions against over 3000 sanctions lists, PEP databases and adverse media. Plus, we update these lists every 15 minutes. Simultaneously, our tools generate auto-alerts when they detect a match or suspicious activity. Moreover, thanks to our risk-based rule engines, you can allocate your resources and compliance efforts on higher-risk cases. Last but not least, our software records all necessary documentation for future audits. These can also help you conduct internal reviews and thus, improve the monitoring process. This is only a part of what we provide, you can contact us to learn more.
FAQ's Blog Post
Ongoing monitoring is the continuous review of customer activity to detect suspicious behavior or risk changes. It ensures businesses remain compliant with AML regulations over time.
It helps identify changes in customer risk profiles, detect unusual transactions, and prevent money laundering. Without it, businesses risk non-compliance and financial penalties.
Monitoring frequency depends on the customer’s risk level—high-risk profiles require more frequent reviews. Many institutions use automated tools to track changes in real time.
AML software platforms offer real-time alerts, transaction monitoring systems, and behavior analysis features. These tools reduce false positives and support compliance teams efficiently.
Yes, most AML regulations globally require ongoing monitoring as part of a risk-based approach. FATF, EU AML directives, and U.S. FinCEN guidelines all mandate it.
Yes, it helps detect patterns consistent with fraud or money laundering. By analyzing behavioral anomalies, businesses can act before major damage occurs.
Initial KYC is a one-time identity check, while ongoing monitoring continuously assesses customer behavior and risk. Both are essential components of AML compliance.
Use risk-based segmentation, real-time alerts, and integrate sanctions/PEP updates. Automating reviews and maintaining audit trails also strengthen compliance.
