With so many risks around, risk mitigation has become lifesaving for financial institutions. To effectively mitigate the risks associated with money laundering, terrorist financing (ML/TF), fraud, and other illicit activities, institutions must adopt proactive measures that go beyond traditional risk management practices.
One such approach is the concept of ongoing customer review and monitoring. In this article we will examine some practical and effective steps that companies have found in implementing ongoing customer review and monitoring to fortify their risk mitigation efforts.
1. Understanding Ongoing Customer Review and Ongoing Transaction Monitoring
Ongoing customer review and ongoing transaction monitoring are different, yet interconnected components of risk mitigation in financial institutions. While both are essential for fulfilling regulatory obligations and combating financial crime, they serve different purposes. Here’s how they differ:
- Ongoing Customer Review: Ongoing customer review primarily focuses on assessing and understanding the customer’s risk profile. It involves continuous evaluation of customer information, identification of changes or inconsistencies in the customer’s profile, and enhancing due diligence procedures.
The goal is to maintain an accurate and up-to-date understanding of the customer’s background, risk appetite, and potential exposure to illicit activities.
- Ongoing Transaction Monitoring: Ongoing transaction monitoring targets detecting unusual or suspicious transactions. It involves continuous monitoring of customer transactions, patterns, and activities, utilizing advanced technology and data analytics.
By analyzing transactional data in real-time or near-real-time and applying predefined red flag criteria, financial institutions can promptly identify and investigate potentially illicit activities.
2. Key Components of Ongoing Customer Review and Monitoring:
For ongoing customer review and monitoring to be effective, regulated entities must perform several key components.
- Ongoing Customer Review: Ongoing customer review includes evaluating customer information and profiles, updating and validating customer data, identifying changes or inconsistencies in the customer’s profile, and enhancing due diligence procedures where necessary. This process must be performed regularly and based on the risk profile of each customer.
These steps ensure that financial institutions maintain accurate and up-to-date information about their customers, enabling effective risk assessment and mitigation.
- Transaction Monitoring: Transaction monitoring encompasses detecting unusual or suspicious transactions, monitoring transaction patterns and behaviors, and utilizing advanced technology and data analytics.
These practices are ongoing and performed throughout the duration of a business relationship. They enable financial institutions to proactively identify potential red flags and mitigate risks associated with ML/TF and other illicit activities.
3. Benefits of Ongoing Customer Review and Monitoring:
Implementing ongoing customer review and monitoring brings several benefits to financial institutions.
- Early detection and prevention of financial crimes: Continuous monitoring of customer activities enables the prompt detection and mitigation of potential risks, preventing money laundering, terrorist financing, and other illicit activities.
- Enhanced regulatory compliance: Ongoing customer review helps institutions meet regulatory obligations by demonstrating their commitment to effective risk management and due diligence. It contributes to a robust AML/CFT framework.
- Protection of institution’s reputation and customer trust: Proactive identification and mitigation of potential risks help financial institutions maintain their reputation as responsible and trustworthy entities, fostering customer confidence and loyalty.
Looking ahead, ongoing customer review and monitoring will continue to play a crucial role in risk mitigation for financial institutions. As the landscape of financial crimes evolves and new risks emerge, institutions must stay vigilant and adapt their review and monitoring practices accordingly.
