What is ongoing monitoring (re-screening)?
A customer screened once at onboarding has been measured against a list that has since moved. Ongoing monitoring is the duty to keep the relationship under review: scrutinise transactions, keep documents and data current, and re-screen as the lists change.
Ongoing monitoring is the fourth limb of customer due diligence under FATF Recommendation 10 and the EU framework, and it is the limb most often under-resourced. Sanctions lists are amended several times a week, ownership changes without notice, and a customer onboarded three years ago may now be a PEP. Re-screening is how a firm finds out. Against a list that moves weekly, an annual review leaves a gap of up to twelve months.
What this workflow covers
SCOPE- Re-screen the customer base on a defined cadence and after significant list updates, routing alerts to review and recording every disposition.
- A designation round that adds an alias to an existing entry can produce a new candidate against a dormant account overnight.
- Carry previous dispositions forward and re-show a candidate only when the underlying record changes, or the queue trains analysts to close alerts without reading them.
- Continuous monitoring comes with the monthly plans and is currently in Beta; scheduled re-runs bill at the ordinary per-check rate.
- This is not only transaction monitoring, and not a periodic refresh of paperwork.
Compliance glossary
TERMS- Re-screening
- Running an existing customer or counterparty through screening again so that new designations and amended entries are caught.
- Alert fatigue
- The degradation of review quality that follows when a screening configuration produces more repeat candidates than analysts can meaningfully assess.
Authoritative references
SOURCES- 01The FATF Recommendations — Recommendation 10 (Ongoing due diligence)
Financial Action Task Force
- 02Regulation (EU) 2024/1624 — ongoing monitoring of the business relationship
EUR-Lex, Official Journal of the European Union
- 03OFAC Recent Actions
U.S. Department of the Treasury — OFAC
Frequently asked questions
Q&A- How often should we re-screen against sanctions lists?
- As close to list-update frequency as the programme allows. Major authorities amend lists several times a week, so daily or continuous re-screening is what keeps exposure short. Risk tiering can set how quickly alerts are reviewed, not whether screening happens.
- What counts as a trigger event?
- A change that forces a reassessment outside the normal cycle: a change of beneficial ownership, a new jurisdiction, an unexpected transaction pattern, adverse media, or a new designation affecting a connected party.
- Does monitoring have to be automated?
- Not legally, and manual re-screening of a book of any size cannot keep pace with list updates. What a supervisor looks at is whether the cadence is defined, applied consistently and evidenced with dated results.