Ongoing monitoring is one of the most critical — and most scrutinised — pillars of modern Anti-Money Laundering (AML) compliance. While onboarding and initial Customer Due Diligence (CDD) establish a baseline understanding of who a customer is, it is ongoing monitoring that determines whether an institution can identify evolving Money Laundering (ML) and Terrorist Financing (TF) risks over time. Globally, regulators have shifted from static, checklist-based compliance to dynamic, risk-based supervision, and the UAE is firmly aligned with this direction.
Under the UAE’s rapidly evolving AML/CFT regime, ongoing monitoring is no longer viewed as a supporting control but as a core, continuous obligation. Financial institutions, Designated Non-Financial Businesses and Professions (DNFBPs), and Virtual Asset Service Providers (VASPs) are all expected to demonstrate that customer relationships and transactions are actively reviewed, risk-rated, and escalated where necessary.
This guide explains what ongoing monitoring means in regulatory terms, how it fits within UAE law, and how organisations can operationalise it effectively.
What Is Ongoing Monitoring?
Ongoing monitoring refers to the continuous review of customer relationships, transactions, and risk profiles throughout the lifecycle of a business relationship. Its primary purpose is to ensure that transactions are consistent with the institution’s knowledge of the customer, their business, and their risk rating, and to identify unusual or suspicious activity that may indicate ML or TF.
From a regulatory perspective, ongoing monitoring has two inseparable dimensions. First, it involves transaction monitoring: analysing customer activity to detect patterns, behaviours, or anomalies that deviate from expected norms. Second, it includes the periodic review and updating of customer information, including beneficial ownership, source of funds, and risk classification. Together, these elements ensure that risk assessments remain accurate and current rather than frozen at onboarding.
Globally, ongoing monitoring is embedded in AML/CFT frameworks such as the Financial Action Task Force (FATF) Recommendations, particularly Recommendation 10 on customer due diligence and Recommendation 20 on suspicious transaction reporting. These standards require institutions to scrutinise transactions throughout the relationship and keep customer information up to date. The UAE, as a FATF member, has incorporated these expectations directly into its domestic legal and supervisory framework.
It is important to distinguish ongoing monitoring from initial onboarding. Onboarding is a one-off or time-bound exercise focused on identifying and verifying a customer before establishing a relationship. Ongoing monitoring, by contrast, is continuous. It responds to changes in customer behaviour, external risk factors (such as sanctions updates), and internal risk assessments. In practice, failures in ongoing monitoring — not onboarding — are among the most common root causes of regulatory enforcement actions, both globally and within the UAE.
Regulatory Framework for Ongoing Monitoring in the UAE
UAE AML Law & Key Regulations
Ongoing monitoring obligations in the UAE are primarily grounded in Federal Decree-Law No. 10 of 2025 on Anti-Money Laundering and Combating the Financing of Terrorism and Illegal Organisations, as amended, and its implementing Cabinet Decisions and sector-specific regulations. These laws apply broadly across financial institutions, DNFBPs, and, more recently, VASPs.
The legislation requires all regulated entities to apply ongoing due diligence measures to business relationships and transactions, proportionate to the customer’s risk level. This includes continuous scrutiny of transactions, ensuring that documents, data, and information collected under CDD remain up to date, and applying enhanced measures for higher-risk customers. Supervisory authorities — such as the Central Bank of the UAE, the Securities and Commodities Authority, and various DNFBP regulators — explicitly assess ongoing monitoring frameworks during inspections.
A critical linkage exists between ongoing monitoring and suspicious transaction reporting. Where monitoring identifies unusual or suspicious activity, entities are legally obligated to submit Suspicious Transaction Reports (STRs) or Suspicious Activity Reports (SARs) to the UAE Financial Intelligence Unit (FIU) via the goAML platform, without tipping off the customer. Inadequate monitoring directly undermines this reporting obligation and is treated as a serious compliance failure.
Underlying these requirements is the risk-based approach. UAE AML law mirrors FATF expectations by allowing — and requiring — institutions to calibrate the intensity and frequency of monitoring based on risk. Higher-risk customers, products, geographies, and delivery channels must be subject to more frequent reviews, deeper transaction scrutiny, and enhanced escalation controls.
Industry-Specific Considerations
While the core legal principles apply universally, implementation varies by sector. Financial institutions are expected to operate sophisticated transaction monitoring systems capable of analysing large transaction volumes in near real time. This includes rule-based alerts, scenario testing, sanctions and politically exposed person (PEP) screening, and behavioural pattern analysis.
DNFBPs — such as real estate brokers, dealers in precious metals and stones, auditors, and legal professionals — face tailored monitoring expectations reflecting their business models. Monitoring often focuses on high-value or complex transactions, changes in ownership structures, and unusual payment methods. For DNFBPs, CDD refreshes are frequently triggered by specific events, such as a new transaction above a regulatory threshold or a change in beneficial ownership.
VASPs occupy a particularly high-risk category under UAE supervision. Ongoing monitoring in this sector includes blockchain analytics, wallet screening, transaction tracing, and enhanced scrutiny of cross-border virtual asset transfers. Regulators expect VASPs to demonstrate a clear understanding of typologies unique to digital assets.
Across all sectors, a distinction is made between periodic reviews and trigger-based reviews. Periodic reviews occur at predefined intervals — annually for high-risk customers, for example — while trigger-based reviews are initiated by events such as unusual transaction patterns, negative media, sanctions updates, or changes in customer behaviour.
Core Components of Ongoing Monitoring
Customer Due Diligence (CDD) Refresh
CDD refresh is the process of updating customer information and reassessing risk on an ongoing basis. This includes confirming identity details, beneficial ownership, business activities, source of funds, and geographic exposure. In the UAE, regulators expect refresh frequencies to align with risk ratings, with enhanced due diligence applied to high-risk customers.
Lifecycle changes are a key focus. Address changes, ownership restructuring, new lines of business, or significant growth in transaction volumes can all materially alter a customer’s risk profile. Effective ongoing monitoring frameworks ensure these changes are captured promptly and reflected in updated risk assessments.
Transaction Monitoring Systems
Transaction monitoring systems form the operational backbone of ongoing monitoring. These systems may be rule-based, using predefined thresholds and scenarios, or incorporate machine-learning models that identify behavioural anomalies. Common techniques include velocity checks, peer-group analysis, and pattern recognition across time and channels.
In the UAE context, regulators do not mandate specific technologies but expect systems to be commensurate with the size, complexity, and risk exposure of the institution. Poorly calibrated thresholds that generate excessive false positives are viewed as a governance weakness rather than a mitigating factor.
Sanctions, PEP & Adverse Media Screening
Ongoing monitoring requires continuous screening of customers and transactions against updated sanctions lists, PEP databases, and adverse media sources. Unlike onboarding screening, which is point-in-time, ongoing screening captures emerging risks — such as a customer becoming a PEP or being added to a sanctions list after the relationship has begun.
Positive matches must trigger escalation, risk reassessment, and, where required, enhanced due diligence or reporting. In the UAE, failures in ongoing sanctions screening are treated as particularly serious given the jurisdiction’s emphasis on international cooperation and compliance.
Red Flags, Alerts & Suspicious Activity Reporting (SAR/STR)
Effective ongoing monitoring depends on clearly defined red flags and escalation pathways. Red flags may include unexplained changes in transaction behaviour, use of complex structures without economic rationale, or activity inconsistent with the customer’s profile.
When alerts are generated, they must be reviewed promptly by trained personnel. Where suspicion cannot be reasonably dismissed, an STR or SAR must be filed through goAML. Importantly, ongoing monitoring is not complete until alerts are resolved, documented, and — where applicable — reported.
Challenges & Best Practices
Common Challenges in Ongoing Monitoring
One of the most pervasive challenges is data quality. Incomplete or outdated customer information undermines both transaction monitoring and risk assessment. Alert fatigue is another significant issue, particularly in institutions with poorly tuned systems that generate high volumes of low-quality alerts.
Technology integration also poses difficulties. Disconnected onboarding, transaction, and screening systems can result in fragmented risk views. Finally, balancing automation with human judgement remains a challenge; over-reliance on automated tools can lead to missed contextual risks, while excessive manual review strains resources.
Best Practices for UAE Entities
Best practice begins with a clearly documented, risk-based monitoring framework aligned to UAE regulatory expectations. CDD refresh schedules should be explicitly linked to risk ratings, with flexibility to initiate ad-hoc reviews when triggers arise.
Real-time or near-real-time transaction analytics enhance detection capabilities, particularly for high-risk customers. Institutions should also maintain detailed monitoring policies and procedures, as these are routinely reviewed during regulatory inspections.
Ongoing staff training is essential. Typologies evolve rapidly, especially in areas such as trade-based money laundering and virtual assets, and regulators expect front-line and compliance staff to remain current.
Measuring Success & Ensuring Compliance
The effectiveness of ongoing monitoring can be measured through key performance indicators such as false-positive rates, investigation turnaround times, and the quality of STRs submitted. These metrics provide insight into both system performance and staff capability.
Audit trails and record keeping are equally critical. UAE law requires AML records — including monitoring outputs and investigation files — to be retained for at least five years. Clear documentation is often the determining factor in regulatory assessments.
Governance structures underpin all of this. Senior management and AML committees must have visibility into monitoring outcomes, key risks, and remediation actions, reinforcing accountability at the highest level.
Conclusion – Future-Ready Ongoing Monitoring
Ongoing monitoring is no longer optional or peripheral; it is the cornerstone of effective AML compliance in the UAE. As regulatory expectations continue to rise, institutions must move beyond static controls toward adaptive, intelligence-driven monitoring frameworks. Advances in AI, automation, and data analytics will shape the future, but regulatory success will still depend on sound governance, skilled human oversight, and a genuine commitment to risk-based compliance. Get in touch with us to avail GRC Services in UAE.
Frequently Asked Questions
What is ongoing monitoring in AML?
Ongoing monitoring is the continuous review of customer relationships, transactions, and risk profiles to detect money laundering or terrorist financing throughout the lifecycle of a relationship.
How often should customer CDD be refreshed in the UAE?
CDD refresh frequency is risk-based. High-risk customers typically require annual or more frequent reviews, while lower-risk customers may be reviewed less often, subject to triggers.
Is transaction monitoring mandatory under UAE AML law?
Yes. UAE AML regulations require ongoing scrutiny of transactions to ensure they are consistent with the institution’s knowledge of the customer and to identify suspicious activity.
What triggers enhanced ongoing monitoring?
Triggers include unusual transaction patterns, changes in customer ownership or activity, sanctions or PEP status updates, adverse media, and high-risk geographies or products.
How does ongoing monitoring link to STR/SAR reporting?
Ongoing monitoring identifies suspicious activity. When suspicion cannot be reasonably ruled out, entities must file an STR or SAR with the UAE FIU via goAML.
