Ongoing monitoring
Checked against the official texts on .
Ongoing monitoring is the continuing scrutiny of an established business relationship — its transactions and the customer's information — to check that activity stays consistent with what the firm knows about the customer and to keep due-diligence data up to date. Under the AMLR, customer information must be refreshed at least once a year for higher-risk customers and at least every five years for all others.
Also called: ongoing due diligence, periodic review, customer refresh, perpetual KYC (when event-driven).
Why it matters for PSPs and EMIs
Onboarding is a snapshot; a merchant's business, owners and sanctions exposure change afterwards. For payment and e-money institutions, ongoing monitoring combines two things: watching transactions against the expected profile, and refreshing the customer file when time passes or something changes.
What the law says
The duty. AMLR Art. 20(1)(f) and Art. 26(1): monitor the relationship, including transactions, to ensure consistency with the firm's knowledge of the customer, its business and risk profile and, where necessary, the origin and destination of funds; and detect transactions that need a closer assessment for possible reporting.
Refresh intervals. AMLR Art. 26(2): the interval depends on risk and may not exceed 1 year for higher-risk customers subject to enhanced due diligence, and 5 years for all other customers.
Event-driven reviews. AMLR Art. 26(3): also review when a customer's relevant circumstances change, when the firm must contact the customer about beneficial ownership during the year, or when it becomes aware of a relevant fact.
Sanctions. AMLR Art. 26(4): verify regularly whether the customer or its owners are subject to targeted financial sanctions; credit and financial institutions also do so upon any new designation.
Guidance to come. AMLR Art. 26(5): AMLA guidelines on ongoing monitoring. AMLA has consulted on a draft; on its overview of 28 September 2026 the guidelines were not yet final.
Current law. Directive (EU) 2015/849, Art. 13(1)(d) and Art. 14(5), as transposed nationally.
International standard. FATF Recommendation 10.
How ProofVolt handles it
ProofVolt keeps every source, step and decision of a case in an append-only trail, so a later review starts from a record of what was established, from which source, and why.
Related
Sources
Informational only, not legal advice.