Ongoing Monitoring

Purpose

An initial due diligence assessment reflects a point in time. Ongoing monitoring identifies material changes — a new sanctions listing, adverse media, or a change in corporate structure — that arise after that assessment.

Scope

Monitoring scope is agreed with the commissioning organisation and typically includes re-screening against sanctions, PEP and watchlist sources, adverse media monitoring, and tracking of corporate registry filings for changes in ownership, control or status.

Typical commissioning circumstances

• An ongoing customer, supplier or counterparty relationship.
• A relationship previously assessed as higher risk.
• A regulatory or internal requirement for periodic re-assessment.

Sources and methods

Monitoring uses the same categories of licensed data and public record sources as the initial assessment, checked on an agreed schedule or triggered by a relevant change event where the underlying data source supports it.

Deliverables

A monitoring alert is issued when a material change is identified, describing the change and its source. A periodic summary confirming no material change is also provided where agreed.

Limitations

Monitoring is only as timely as the underlying source data. It does not guarantee that every relevant change will be identified immediately upon occurrence.

Confidentiality

Monitoring alerts and summaries are provided to the commissioning party only and are not published in the registry.

Review process

Where a subject disputes a monitoring alert, they may request review through the review and correction process.