Traditional KYC is still largely point-in-time: a customer is assessed at onboarding and then formally reviewed months or years later. But customer risk does not stand still between reviews. Ownership, directors, addresses, behaviour or other risk factors can change after onboarding and may only be discovered at the next scheduled review.
The shift towards a Continuous System of Control is about identifying material change when it happens, continuously monitoring relevant client data, documents, relationships and risk signals, and triggering the appropriate action rather than waiting for the calendar to initiate a review.
