Ongoing Monitoring

Relevant Law/ Regulation: Counter-Terrorism Act 2008 Part 3 (4), Money Laundering Regulations 20(a)

Ongoing Monitoring Obligations:

  • Must carry out prescribed customer due-diligence measures for all customers not covered by exemptions
  • Must have systems to deal with identification issues in relation to those who cannot produce the standard evidence
  • Must apply enhanced due-diligence to take account of the greater potential for money laundering in higher risk cases, specifically when the customer is not physically present when being identified, and in respect of Politically Exposed Persons
  • Some persons/entities must not be dealt with
  • Must have specific policies in relation to the financially (and socially) excluded
  • If satisfactory evidence of identity is not obtained, the business relationship must not proceed further
  • Must have relevant system for keeping customer information up to date
  • Must conduct ongoing sanction screening
  • Ongoing Identification of AML/CTF typologies and update systems and controls accordingly