Updated

GL-O-03

Glossary · Due Diligence and compliance

Ongoing monitoring - Ongoing monitoring

Ongoing monitoring — a bank continuing to observe a client and their transactions after onboarding, rather than a one-off check.

Full glossary
continuouslynot one-off
transactionsunder observation
transparencyalways matters

01 / In 30 seconds

The short answer

What it is
Ongoing monitoring — a bank’s observation of a client after onboarding
Not one-off
The check continues rather than ending when the account is opened
What is monitored
Transactions, changes in profile, new risks
Why
Detect suspicious activity in time
How to use it
Keep transactions transparent and explainable

02 / In plain words

What Ongoing monitoring means

Ongoing monitoring is the principle under which the check on a client does not end when the account is opened but continues throughout the relationship. A bank or financial institution constantly observes how the client uses the account: what transactions they carry out, whether these match their declared profile, and whether new risks have appeared.

In practice this means automated and manual transaction monitoring: the system tracks unusual amounts, atypical payment destinations and sudden changes in activity, and periodically updates the client’s data and re-screens them against sanctions and other lists. If something falls outside the expected picture, the bank may request explanations, suspend a transaction or, in serious cases, report to the regulator.

The practical conclusion for the client: passing the check when opening an account is not the end but the start of a relationship under observation. Sudden large or unexplained transactions that do not fit the declared profile may raise questions and even lead to a block. We help clients build transparent and explainable financial activity from the outset, so that ongoing monitoring does not lead to unexpected blocks.

A case from practice

A client opened an account and six months later carried out a large atypical transaction — and the bank suspended it, requesting explanations. We prepare clients in advance for the fact that monitoring is continuous: we support large transactions with documents and an explanation so that they do not cause blocks.

Where ongoing monitoring matters

  • Running a bank account
  • Carrying out large transactions
  • Changes in the nature of activity
  • Updating client data
  • Handling international payments
  • Keeping access to the account

03 / What it covers

What matters about ongoing monitoring

01

What it is

  • Observation after onboarding
  • Not a one-off check
  • Throughout the relationship
02

What is monitored

  • Transactions and amounts
  • Consistency with the profile
  • New risks
03

Tools

  • Transaction monitoring
  • Updating data
  • Re-screening
04

Consequences

  • Requests for explanation
  • Suspending a transaction
  • Reporting to the regulator

04 / How it works

How monitoring works

Step 1

Onboarding

Step 2

Observing transactions

Step 3

Detecting unusual activity

Step 4

Requesting explanations where needed

Step 5

A stable relationship

05 / Key facts

What you need to know

01

Ongoing monitoring is observation after onboarding

02

The check does not end when the account is opened

03

Transactions and consistency with the profile are monitored

04

Data are periodically updated and re-screened

05

Unexplained activity may lead to a block

Common mistakes

  • Assuming there are no more checks after the account is opened
  • Carrying out transactions that do not fit the declared profile
  • Not preparing explanations for large transactions
  • Changing activity sharply without explanation
  • Ignoring the bank’s requests to update data

06 / Expert advice

Dmitry Nagy

How to prepare in advance

The relationship with the bank is built so that activity is always transparent and consistent with the declared profile. For large or atypical transactions an explanation and documents are prepared in advance, and requests to update data are answered on time. Then ongoing monitoring goes smoothly, and the account is not blocked because of a transaction the bank found unexplained.

What we do for you. We help build the relationship with the bank so that ongoing monitoring does not lead to blocks: from the outset we make financial activity transparent and explainable, and we support large transactions with documents. That way the account works steadily rather than freezing because of an unexpected question from compliance.

Dmitry NagyTax consultant, international taxation and compliance (ex-Big4)

07 / Questions

Frequently asked questions

The principle under which the check on a client continues throughout the relationship rather than ending when the account is opened. The bank observes the client’s transactions and profile.

Correct. Passing the check when opening an account is the start of a relationship under observation, not the end. Activity is monitored continuously.

Unusual amounts, atypical payments, sudden changes in activity, the consistency of transactions with the profile, and it periodically re-screens the client against lists.

Sudden large or unexplained transactions that do not fit the declared profile. They may lead to a request for explanations, a suspension or a block.

Keep activity transparent and explainable, support large transactions with documents and answer the bank’s requests on time. We help set this up.

In serious cases of suspicious activity, yes — the bank is obliged to report to the regulator. That is why transparency of transactions matters throughout the relationship.

Author: Dmitry Nagy

Reviewed by: Klara Rihter

Sources: FATF — on ongoing customer monitoring

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Anna Kovalevskaya, lead lawyer at BRIDGES GLOBAL
Anna KovalevskayaLead lawyer, citizenship and residency, 12 years of practice