With the FCA placing increased scrutiny on corporate ongoing monitoring practices, firms are under pressure to ensure their frameworks are not only compliant, but demonstrably robust. Internally, firms are also seeking operational efficiency in their processes. One of the key ways of achieving this is through data.
However, the challenge is how much data is enough when assessing changes to a customer’s profile.
Following our recent webinar, we explored how firms can optimise their approach to periodic and trigger-based reviews, balancing operational efficiency with evolving regulatory expectations and use of data.
Here are some of the key takeaways from the session, including insight from our expert panel:
Reperformance vs Risk-Based Approaches
‘Reperformance’ is the application of conducting all client due diligence as part of your ongoing monitoring. Taking a ‘Risk–based’ approach or dynamic approach is where you consider the risk posed as the driver for the level of due diligence completed.
Both approaches play an important role in effective ongoing monitoring, and firms should avoid viewing them as mutually exclusive.
The key is to assess the materiality of any change to the customer profile. If the change is assessed as minor or low risk, a targeted, risk-based approach may be more appropriate. However, in cases of significant changes, such as new ownership structures or transactional activity outside of the stated level, a fuller reperformance of all customer due diligence may be warranted.
“Just because someone's passport has expired, it doesn't mean their risk profile has changed.”
Bion Behdin
A risk-based approach enables firms to focus time and resources where they’re most needed, helping prevent unnecessary duplication of effort. Meanwhile, reperformance can serve as a valuable control mechanism to ensure consistency in the treatment of higher-risk relationships.
Tools and Data
Effective ongoing monitoring isn’t just about process; it also depends on the quality and structure of your data, and the tools you use to manage it. Many firms have screening systems, case management tools, and CRMs in place, but these systems are often fragmented or misaligned. Without clear integration and visibility across the customer lifecycle, inefficiencies quickly build up.
“We're now building a live profile of the customer that reflects changes almost as they happen.”
Iva Teneva
A holistic view of your technology infrastructure is essential. Consider how customer information is captured, stored, reviewed and updated across onboarding, trigger events, and periodic reviews. We also revisited the build vs buy decision, with discussion around how firms are assessing whether to develop in-house solutions or implement configurable, external platforms that can evolve with the business.
Operational Efficiencies
An effective ongoing monitoring framework begins with the process itself. Without a clear structure for managing reviews, even the best systems and tools won’t prevent backlogs or bottlenecks. The starting point should be a well-defined review schedule, informed by the customer’s risk profile and supported by clear, risk-led triggers.
“Operational efficiency – the easiest place to gain that is in your compliance programme.”
Bion Behdin
The right process should also take pressure off internal teams. Rather than relying on reactive fixes or one-off remediation exercises, firms can use structured monitoring to maintain control, improve case management and ultimately support better decision-making. It’s also important that staff responsible for monitoring are trained not only in the process, but in the underlying risks and regulatory expectations that drive it.
Watch the full session now
How Thistle Initiatives can help
At Thistle Initiatives, we understand the challenges involved in maintaining effective oversight while keeping pace with change. If your firm is looking to review or enhance its approach to ongoing monitoring, we’re here to help.
Get in touch with our financial crime team to find out how we can support your firm with tailored insight, tools and expertise.
Meet the expert
Leanda Mark-Ihama, Senior Manager, Financial Crime 
Leanda has over 14 years’ financial crime experience, including in the banking industry and at the FCA, and has completed the CAMs certification, ICA Financial Crime Prevention Diploma and ICA Anti-corruption certificate. Leanda has extensive expertise in both AML and ABC, building and assuring frameworks.