Why one-time screening falls short

Sanctions lists are dynamic - new designations and delistings occur multiple times per week across major lists including OFAC SDN, EU Consolidated, UN Security Council, and UK OFSI. A customer screened as clear at onboarding may become a sanctioned party the following day. One-time screening creates a gap between the moment of checking and any subsequent list update.

The FATF Recommendations explicitly require ongoing monitoring of business relationships, including keeping CDD information up to date and scrutinising transactions throughout the relationship.

Regulatory requirements for ongoing monitoring

The UK Money Laundering Regulations 2017 require firms to conduct ongoing monitoring of business relationships, including scrutiny of transactions and keeping documents and information up to date. Research from the Journal of Financial Stability found that ongoing monitoring catches significantly more true positives than point-in-time screening alone.

Approaches to ongoing monitoring

There are three common ways to keep screening current, and many firms use them together.

Periodic batch rescreening

Batch screening your entire customer portfolio at regular intervals - monthly, quarterly, or as determined by your risk-based approach. This catches any customers who have been newly designated since their last screening.

Event-driven rescreening

Automated alerts triggered when sanctions lists are updated, prompting immediate rescreening of active customers. This provides the fastest response to new designations and is the approach used by FirmScreen's ongoing monitoring feature.

Trigger-based reviews

Rescreening when specific events occur: a change in customer details, a new transaction above a threshold, or a change in the customer's risk profile. TCSPs managing ongoing entity relationships should rescreen when directors, shareholders, or beneficial owners change.

Building an ongoing monitoring programme

A workable monitoring programme comes down to a few decisions, made once and written down.

  • Define monitoring frequency by risk tier: High-risk customers monthly, standard-risk quarterly, lower-risk annually
  • Automate where possible: Manual rescreening is error-prone and resource-intensive
  • Document everything: Maintain complete audit trails of all rescreening activity
  • Assign responsibility: Your MLRO should oversee the monitoring programme

For a comparison of batch and real-time approaches, see our guide on batch vs real-time screening.