A monitoring regime means you can monitor and review your AML/CTF program at a number of different levels. A framework of monitoring and review practices could include monitoring that differs in its frequency and scope and could be described as:

• continuous
• regular
• selective.

Continuous monitoring should ideally be built into your business processes so that AML/CTF processes are correctly completed whenever an overlying process is conducted; for example, that customer due diligence is completed whenever a customer applies for a new designated service, or AML/CTF awareness training is provided for each new employee. This is the sort of checking that is within the control of the staff members who are following the process, as well as their supervisors.

Regular monitoring may be associated with line management reviews of the business unit, that identified AML/CTF performance measures are being met over a certain period and if not, that corrective action can be taken. Such measures may be more selective, but will be routine in that they may form the basis of weekly, monthly or quarterly reports on AML/CTF compliance.

Selective monitoring is of lower frequency than continuous or regular monitoring. It will tend to be programmed to assess performance of the systems that contribute to the effectiveness and capability of the whole of the AML/CTF program. It may take the form of internal and external audit processes and these audits may be set up as independent reviews of the AML/CTF program.