Ongoing monitoring

This includes:

• Keeping client records current
  
• Tracking changes in behaviour or business activity
  
• Updating policies and procedures
  
• Monitoring transactions (where relevant)
  
• Reviewing your AML systems and internal controls
  
  

Monitoring should happen routinely, and in response to trigger events — like suspicious activity, new legislation, or changes in client risk.

Why it matters

AML compliance isn’t a one-time task. Clients change. Regulations evolve. Risk profiles shift. Without regular reviews, your firm could miss warning signs or rely on outdated information — exposing you to potential breaches, missed red flags, and regulatory penalties.

Ongoing monitoring helps you:

• Detect and respond to unusual behaviour
  
• Confirm that your documentation reflects reality
  
• Strengthen internal controls and team accountability
  
• Demonstrate a proactive compliance culture
  
  

Done well, it’s not just protection — it’s an opportunity to support clients better and build trust.

How to carry out effective ongoing monitoring

1. Review your policies and procedures

Start by checking that your AML policies reflect industry guidance and the way your firm actually works.

• Are your controls still relevant to the risks you face?
  
• Have your services or client types changed?
  
• Do staff understand and follow the documented procedures?
  
• Have any new requirements been introduced since your last review?
  
  

Keeping your policy documents updated not only ensures compliance — it helps your team stay aligned and confident in what’s expected.

2. Monitor client information

Regularly revisit your client profiles to confirm they’re still accurate and complete.

• Have there been changes in ownership, business activity, or structure?
  
• Does the risk level still feel appropriate?
  
• Are documents like IDs, risk assessments, and KYC records current?
  
  

The depth and frequency of your reviews should match the client’s risk level. Higher-risk clients will need closer, more frequent attention. And remember — ongoing monitoring differs from enhanced due diligence. The former is routine; the latter is targeted, in-depth, and risk-driven.

3. Monitor transactions (where applicable)

If your firm is involved in handling or reviewing client transactions, you’ll also need to carry out transaction monitoring.

This helps you:

• Spot unusual patterns
  
• Identify transactions that don’t fit with the expected client profile
  
• Respond early to potential red flags
  
  

Not all firms need automated transaction monitoring, but if you are regularly processing or overseeing funds, this should be part of your ongoing AML checks.

4. Keep detailed records

Good record keeping supports both compliance and internal audit readiness. You should easily be able to show:

• What documents were collected
  
• When they were last reviewed or updated
  
• What changes were made and why
  
• Who carried out the review
  
  

Ensure records are clearly labelled, securely stored, and accessible to relevant team members. Timestamps and audit trails are essential for showing ongoing effort.

5. Review your controls and technology

Ongoing monitoring should also include reviewing how your firm operates — not just your clients.

• Are staff following the correct procedures?
  
• Is your technology doing what it should — and flagging issues when needed?
  
• Are there any gaps in how manual work is being checked?
  
  

Use this as an opportunity to tighten processes, improve workflows, and address weaknesses before they lead to compliance failures.

Summary

Ongoing monitoring is a core part of your AML obligations — and a key line of defence against changing risk. It’s how you ensure your client records, policies, and systems continue to reflect the real-world situation.

To stay compliant:

• Review your AML policies and procedures regularly
  
• Keep client information and risk assessments up to date
  
• Monitor transactions where relevant
  
• Maintain clear records with audit trails
  
• Strengthen controls and proactively resolve process issues
  

AML compliance isn’t static — it’s something your firm builds and protects over time. Ongoing monitoring is what keeps it strong.

This article was summarised by the Firmcheck content team. The original content was written by an independent AML expert and is available on our blog.

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