Ongoing monitoring is the requirement to periodically review a client's risk profile after the initial check in order to make sure the information you hold remains accurate and any change in their risk level is identified. It applies for as long as the business relationship continues.
This article provides general information only and is not legal advice.
When ongoing monitoring STOPS
Ongoing monitoring ends when the business relationship ends.
For a residential property sale, the relationship typically ends at settlement. Once the transaction is complete, there is no ongoing monitoring obligation for that client and that matter. You are required to keep the records for 7 years, but you do not need to continue reviewing or monitoring a client after the relationship has concluded.
This makes residential real estate relatively straightforward from a monitoring perspective as most transactions are once off, with a clear end point.
When ongoing monitoring continues
For ongoing client relationships, particularly common in legal practice, monitoring continues for as long as you have an active relationship with the client.
A client who returns to your firm for multiple matters over several years is a client with an ongoing relationship. That relationship requires periodic review even between individual matters, because the client's risk profile may change over time (for example, they may become a PEP, or their source of wealth may change).
Review periods
The frequency of review depends on the client's risk rating:
Risk rating | Review period |
Low risk | Review every 3 years |
Medium risk | Review every 24 months |
High risk | Review every 12 months (minimum — enhanced clients may warrant more frequent review) |
These periods are guidelines based on standard AML/CTF practice. Your firm's AML program may specify different periods and your admin can configure review periods in Workflow to match your program.
Workflow will flag when a client is in their review period so you don't need to track this manually.
What a review involves
A periodic review is a simple re-verification. It is an assessment of whether:
The client's details and identity documents are still current
Their risk rating remains appropriate given any changes in their circumstances
The business relationship is still active and consistent with what you'd expect
If something has changed,for example, the client has been identified as a PEP, this may change their risk assessment.
Document the outcome of every review in the case notes.
The 7-year record-keeping obligation
Whether or not ongoing monitoring applies, you are required to retain all AML/CTF records for 7 years from the end of the business relationship. This includes:
Identity verification records
Risk assessment records
Notes and documents uploaded to the case
The case history and audit trail
Workflow retains all case records for 7 years automatically. You do not need to export or archive anything manually.
Summary: real estate vs. legal professionals
| Residential real estate | Legal professionals |
Transaction type | Typically discrete (ends at settlement) | Often ongoing (client returns for new matters) |
Ongoing monitoring required? | No — ends at settlement | Yes — for the duration of the client relationship |
Review period (low risk) | Not applicable after settlement | Every 3 years |
Review period (medium/high risk) | Not applicable after settlement | Every 12 months |
Record retention | 7 years from settlement | 7 years from end of relationship |
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