3.2.1.4.3 EDD: Ongoing Monitoring
Effective from 16/6/2021When customers are higher risk, monitoring should be more frequent, intensive, and intrusive. LFIs should review the CDD files of higher risk customers on a frequent basis, , such as every six or nine months for very high-risk customers. The methods LFIs use to review the account should also be more intense and should not rely solely on information supplied for the customer. For example, LFIs should consider:
| • | Manually reviewing all transactions on the account on a quarterly basis, rather than a sample of transactions (as discussed above, such manual review should be in addition to automated transaction monitoring). Manual review can take the form of reviewing individual transactions, or of using data analysis to determine information about the customer's activity (e.g., overall percentage of counterparties in high-risk jurisdictions; new jurisdictions of activity compared to last quarter; overall percentage of transactions that are round numbers, etc.) that would not be apparent to automated transaction monitoring systems; | |||
| • | Conducting site visits at the customer's premises and requesting a meeting with the customer's managing director or Chief Financial Officer; | |||
| • | Conducting searches of public databases, including news and government databases, to independently identify material changes in a customer's ownership or business activities or to identify adverse media reports. Searches for adverse media should include relevant key words, including, but not limited to, allegation, fraud, corruption, and laundering. | |||
In addition, higher-risk customers should be subject to more stringent transaction monitoring, such as lower thresholds for alerts and more intensive investigation.