I'm relatively new to the compliance side, coming from operations, and I've been wrestling with the optimal frequency for ongoing AML screening of existing clients. We currently perform annual checks, which I understand meets the basic regulatory requirements for our jurisdiction regarding sanctions lists ($OFAC, etc.) and adverse media.
However, I've heard some chatter, particularly from those dealing with higher-risk client segments or cross-border transactions, about more frequent, even quarterly or monthly, deep dives. The argument is that an annual refresh might miss crucial developments, like a client being added to a PEP list or new adverse media emerging, that could significantly alter their risk profile between those annual reviews.
From a resource perspective, ramping up screening frequency is not a trivial ask, especially for a large client base. So, I'm trying to understand the balance. Are firms generally sticking to the regulatory minimum for lower-risk clients and only escalating for specific high-risk categories, or is there a move towards more proactive, shorter-cycle screening across the board as a de-facto best practice, even if not strictly mandated? What are others in the room doing, and what's driving those decisions?