AMLG11411 - Guidance for all sectors: Ongoing monitoring of business relationships
14.11 Ongoing monitoring of business relationships
You must continue to monitor a business relationship after it is established and for its duration.
As part of this, you must:
- Review customer due diligence information and records to ensure they are up to date, including replacing expired documents with valid copies.
- Review beneficial ownership for corporate clients to ensure it remains accurate.
- Monitor transactions, including (where appropriate) the source of funds, to ensure they are consistent with your knowledge of the customer and their risk profile.
You should also take action where specific triggers arise, including:
- Where you become aware of changes in the customer’s circumstances that could affect their risk assessment.
- Where transactions appear unusual or inconsistent with expected activity.
- Where there are changes relating to high-risk third countries.
- Where there are doubts about the adequacy or accuracy of information previously obtained.
For more detailed information on source of funds and source of wealth, please see AMLG11630.