규모가 작고 '명백하지 않은' 기업 고객에 대한 AML 심사 - 얼마나 깊이 들어가야 할까요?

That's a great point about ongoing monitoring, especially with subtle changes. We've found it helpful to establish clear internal triggers for re-screening, not just based on sector, but also on the nature of the change itself – a new director from a higher-risk jurisdiction would definitely be one of them.

This is something I've been wondering about too. How do you even keep track of those subtle changes without spending a ton of time on each client, especially the smaller ones?

That's a good point about ongoing monitoring, especially with director changes. We usually flag any new directors for a quick scan, even if they're in a low-risk sector, just to be safe. Do you have a trigger for when a 'slight' change becomes a full re-review?