Keep a written record of every step taken when refreshing a customer's information, and re-rate the customer's risk profile to reflect what the refresh found.

Ongoing monitoring of customers, accounts and transactions.

a. Covered persons shall, on the basis of materiality and risk, ensure that pertinent identification information and documents collected under the CDD process are kept up-to-date and relevant by undertaking reviews of existing records, particularly for higher-risk categories of customers. The covered person shall document the actions taken in connection with updating of customer’s records/information, and accordingly update customer’s risk profile.

Covered persons shall establish a system that will enable them to understand the normal and reasonable account or business activity of customers to ensure that the customers’ accounts and transactions are consistent with their knowledge of the customers, and the latter’s commercial activities, risk profile, and source of funds and detect unusual or suspicious patterns of account activity. Thus, a risk- and materiality-based ongoing monitoring of customers’ accounts and transactions, including periodic sanction screening, should be part of a covered person’s customer due diligence.