A 2026 European consultation on continuous monitoring has closed. Its draft guidance covers current client data and the monitoring of transactions and activities. It is not a final rule. Dutch Wwft institutions already have a duty to monitor business relationships and transactions.
Why this matters
Onboarding records capture one point in time. Ownership, authorised representatives, business activities and payment routes may later change. For Wwft institutions, ongoing monitoring is already part of customer due diligence. Tools and external specialists may help, but the firm keeps responsibility. Banks, accountants and payment providers may ask for current ownership records or payment evidence. Missing documents can delay a payment or transaction.
Example
A regular customer’s invoice is paid by its parent company. A new shareholder has joined, and a different employee gives instructions. The file should link the customer, payer, shareholder, authority and invoice. Record the change, the reviewer, the evidence checked, and the decision on the client risk profile. Otherwise, finance, client service and compliance may each hold a piece of the file. No one has recorded the decision.
XTROVERSO tips
- Name the owner. Assign a person or role to each client-file review. Record who approves an update and who handles an unresolved issue.
- Set clear review triggers. List events that require attention, including UBO changes, new representatives, changed activities, new countries and unusual third-party payments.
- Check active files. Compare current ownership, authority, activities and payment patterns with the onboarding record. Start with a small, risk-based sample.
- Keep one evidence trail. Link company records, contracts, invoices, payment details and internal decisions. Do not leave the explanation spread across separate inboxes.
- Record third-party payments. Identify the payer, note the business reason and link the payment to the correct invoice or supply. Escalate gaps under the firm’s procedure.
- Test tools and escalation. Check what screening software or an external provider records and flags. Confirm which decisions need staff review and who makes them.
Need a practical review of client-file triggers, records and responsibilities? We can help turn them into a workable process
The data, sourcing, and analysis behind this article were conducted by Paolo Maria Pavan. AI was not used to identify sources, build the factual basis, or produce the analytical judgment contained here. AI was used only as a drafting aid. The final English text was personally reviewed, edited, and approved by Paolo Maria Pavan before publication.
References
- Bureau Financieel Toezicht — AMLA consultation on continuous monitoring
- Bureau Financieel Toezicht — Wwft frequently asked questions
- Bureau Financieel Toezicht — Warnings and sanctions
- FIU-Nederland — 2025 annual overview
- Dutch Wwft — official legislation database
- Overheid.nl — Legislative transition to the European AML framework
