Ongoing monitoring

What is ongoing monitoring?

Ongoing monitoring means continuing to review your clients and transactions throughout the business relationship — not just at the start. AUSTRAC requires this as part of your AML/CTF program.

Two things are involved:

1. Regular re-screening — re-checking clients against the DFAT Consolidated List on an ongoing basis
2. Transaction review — staying alert to any activity that looks unusual or inconsistent with what you know about the client

Automated re-screening in AML Simple

On Professional and Agency plans, AML Simple automatically re-screens your active clients against the DFAT Consolidated List at regular intervals. You do not need to trigger this manually.

When a re-screen completes, the result is logged to the client record with a timestamp. If a potential match appears, you will receive an alert and need to review it. See Reviewing a potential match.

On Starter and Foundation plans, re-screening must be done manually from the client record.

How often should you re-screen?

AML Simple’s automated re-screening runs on a schedule set in your account settings. A reasonable default for most agencies is monthly re-screening for active clients.

You should also trigger a re-screen immediately when:

• A client’s details change (name, address, nationality)
• A client’s risk rating changes
• The client starts a new transaction with your agency
• You become aware of information that changes your view of the client’s risk profile

What triggers a re-screen manually

From any client record, go to the Screening tab and select Run screen now. The result is logged immediately.

What to watch for in transactions

Ongoing monitoring also means staying alert during the transaction itself. Look for patterns that are inconsistent with what you know about the client — for example, a change in funding source, a request to involve a new third party, or pressure to rush the settlement without normal due diligence.

If something concerns you, escalate to your Compliance Officer. They may decide a Suspicious Matter Report is required.