3.2.4.2 EDD: Ongoing Monitoring

يسري تنفيذه من تاريخ 27/9/2021

When customers are higher risk, such as for cash-intensive businesses rated as high-risk following the completion of the CDD process, monitoring should be more frequent, intensive, and intrusive. LFIs should review the CDD files of higher risk customers on a frequent basis, such as every six or nine months for very high-risk customers. The methods LFIs use to review the account should also be more intense and should not rely solely on information supplied for the customer. For example, LFIs should consider:

	•	Reviewing more or all transactions on the account, rather than a sample of transactions;
	•	Conducting site visits at the customer’s premises, whenever the LFI is not satisfied with the documentation provided by the customer, and requesting a meeting between an appropriate LFI representative and the customer’s managing director or Chief Financial Officer. Site visits can be particularly important for certain cash-intensive businesses, including those that use an LFI’s cash management services on a large scale, as they allow the LFI’s compliance personnel to inspect the institution’s cash management program and the controls it has in place to prevent illicit cash being commingled with legitimate funds; and
	•	Conducting searches of public databases, including news and government databases, to independently identify material changes in a customer’s ownership or business activities or to identify adverse media reports. Such searches should include adverse media searches of public records and databases, using relevant key words, including but not limited to, allegation, fraud, corruption, laundering.