How often should financial institutions (“FIs”) conduct ongoing monitoring of their customers?
Ongoing monitoring is a fundamental feature of an effective Anti-Money Laundering/Countering Financing of Terrorism (“AML/CFT”) risk management system. All FIs may conduct ongoing monitoring according to customer’s money laundering/terrorist financing (“ML/TF”) risk profile. Higher risk customers should be subject to more frequent periodic review (at least annually) to ensure CDD information previously obtained remains relevant and risk profile remains relevant.