Ongoing Monitoring
Re-running sanctions and PEP screening for an existing customer whenever the underlying watchlists change, rather than screening only once at onboarding.
A customer cleared in March is not necessarily clear in June — the customer has not changed, but the lists have. Whether a business finds out depends entirely on its re-screening model. Onboarding-only screening leaves an exposure window that grows unbounded for the life of the relationship. Periodic re-screening (annual, quarterly) leaves an average exposure window of half the cycle length — roughly six weeks on a quarterly cycle — and arrives as a large, spiky review batch rather than a steady stream. Continuous monitoring re-screens affected entities whenever a source list actually changes, bounding the exposure window to the ingestion cadence rather than a calendar.
Regulators generally require ongoing due diligence without prescribing an exact frequency — FATF and OFAC guidance both expect controls to keep pace with how often the underlying lists change, without setting a fixed interval. That silence puts the burden on the institution to show its cadence is proportionate to risk; a monitoring interval measured in months against lists that change in days is a difficult position to defend to an examiner. The standard objection — that continuous monitoring produces more alerts — is answered by threshold tuning and risk-based routing, not by re-screening less often.