ODD & continuous customer monitoring: why real-time KYC is replacing periodic reviews

In today’s regulatory environment, relying on annual or periodic KYC reviews might not be enough. Customers can change address, change jobs, update ownership structures or become politically exposed in a matter of days. Without real-time monitoring, your team risks missing critical updates and exposing the organization to fines, fraud and reputational damage.

That is why continuous customer monitoring, also called ongoing due diligence or real-time KYC, is becoming the new standard for banks, fintechs and regulated businesses.

What is continuous customer monitoring

Continuous monitoring means that instead of updating customer files once a year, your compliance system tracks key data points and risk indicators as they change. For individuals this can include identity, address, professional status and sanction or PEP exposure. For business customers it covers corporate ownership, directorships, business activities and geographical exposure.

In practice, continuous monitoring ensures you always have an up-to-date view of your customer base.

Why periodic reviews are no longer enough

Periodic KYC reviews leave long blind spots.

• Sanction risk when a customer is added to a sanctions list months after onboarding and no refresh is planned
• Ownership changes that alter the risk profile of a company overnight
• Fraud exposure because outdated information makes it harder to detect unusual behavior
• Regulatory pressure as supervisors expect ongoing due diligence rather than point-in-time checks

Annual reviews are reactive. Continuous monitoring is proactive.

Key elements to track in real-time KYC

To maintain reliable customer knowledge, organizations should focus on:

• Sanctions and PEP screening with automated daily checks against updated lists
• Identity changes such as names, addresses, civil status or expired documents
• Professional status such as employment changes, unemployment or retirement
• Corporate ownership with new directors, beneficial owners or legal representatives
• Business activities like expansion into high-risk industries or jurisdictions
• Customer behavior when new product usage or transactions differ from expected patterns

These elements directly influence risk classification and should trigger updates in customer files.

How to implement continuous vigilance in compliance

Adopting real-time monitoring does not have to be overwhelming. The transition typically follows five steps.

1. Apply risk-based segmentation

Not all customers require the same level of monitoring. Define risk classes and tailor monitoring intensity. High-risk customers should be screened more frequently and thoroughly, supported by dynamic risk scoring.

2. Automate sanctions and PEP screening

Manual screening is slow and error-prone. Using automated tools from a scan library ensures customer profiles are checked daily against updated sources.

3. Integrate compliance with CRM and operations

Customer activity often changes outside compliance channels. With centralized case management, activity signals flow directly into compliance workflows so no change is missed.

4. Set triggers for document expiry and profile changes

When an ID expires or ownership data changes, alerts should automatically trigger a review. These checks are built into both user verification and business verification.

5. Use remediation campaigns to collect missing data

Where information is incomplete or outdated, launch targeted outreach. Automated workflows make compliance teams more efficient and improve response rates.

Benefits of real-time customer monitoring

Shifting from periodic to continuous monitoring delivers clear value.

• Stronger compliance because customer files stay current
• Lower fraud risk through faster detection of suspicious changes
• Better customer experience with fewer large catch-up reviews
• Audit readiness with evidence of proactive monitoring available at any time
• Operational efficiency as automation reduces manual checks

Challenges and how to overcome them

Teams often worry about complexity. Here is how to address common hurdles.

• False positives improved by tuning rules and thresholds in risk models
• System silos addressed by connecting operational data with compliance workflows
• Customer friction minimized with transparent communication and self-service updates
• Cost concerns managed with automation powered by prebuilt scans from the scan library

Continuous monitoring in practice: before and after

• Before annual reviews, manual ownership checks, documents verified only at renewal, static risk scores
• After daily sanction and PEP screening, triggered alerts for expired documents, automated checks on ownership changes, dynamic risk scoring

How Ondorse supports ODD and continuous vigilance

Ondorse helps compliance teams automate ongoing due diligence end to end.

• User verification for real-time sanction and PEP screening and event-driven KYC refresh
• Business verification for adaptive KYB and monitoring of ownership changes
• AML risk scoring for continuous customer risk assessment
• Scan library to deploy ready-made controls and alerts
• Case management to centralize decisions and stay audit-ready

Continuous customer monitoring is no longer optional. Moving beyond periodic reviews helps organizations detect risks earlier, reduce compliance costs and improve the customer experience.

If you want to ensure your customer knowledge stays accurate every day and not just once a year, explore how real-time monitoring can transform your approach to KYC and KYB.

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