Ongoing monitoring and keeping CDD records

What ongoing monitoring means

Regulation 28(11) says you must conduct ongoing monitoring of a business relationship, including:

(a) scrutiny of transactions undertaken throughout the course of the relationship (including, where necessary, the source of funds) to ensure that the transactions are consistent with the relevant person's knowledge of the customer, the customer's business and risk profile; (b) undertaking reviews of existing records and keeping the documents or information obtained for the purpose of applying customer due diligence measures up to date.

When to look again

HMRC's guidance says CDD should be applied again when a client's circumstances change significantly, when you doubt information you hold, or when you suspect money laundering or terrorist financing. Sanctions and PEP status can also change after you take a client on, so periodic ongoing screening supports your monitoring.

How long to keep records

Regulation 40 requires you to keep copies of the documents and information you obtained for CDD. The period is five years beginning on the date you know, or have reasonable grounds to believe, that the business relationship has come to an end.