Ongoing compliance guide: ongoing monitoring and perpetual KYC for fund administrators and ManCos
Fredrik Gröndahl2 min readThought Leadership
Ongoing monitoring (the AMLR's term) means keeping a customer's file current for as long as the relationship lasts: updating it when something relevant changes, and reviewing it on a risk-based schedule of at most five years, or one year for higher-risk customers. Perpetual KYC, or pKYC, is the market's name for the same practice, also called continuous or event-driven KYC.
The AMLR makes this a direct obligation from 10 July 2027, and AMLA's guidelines on how to do it are expected in final form in the fourth quarter of 2026. Most of what is written about perpetual KYC is written for banks. This series is written for compliance teams at fund administrators, management companies and corporate service providers in Luxembourg, Mauritius and elsewhere.
Start here
- What is ongoing monitoring under the AMLR? Article 26 explained
- Perpetual KYC: what it means and whether your firm is ready
- Your perpetual KYC pilot still needs an exit test
Evidence and what regulators look for
- What regulators look for in KYC document audits
- Why a KYC platform needs a policy engine, not just a risk score
- Purpose and intended nature: what the Nordea case means for CDD
- OFAC as a risk factor: what the CJEU's Jenec ruling changes about CDD documentation
Beneficial ownership
- UBO identification in layered ownership structures
- What FATF's Singapore verdict says about beneficial ownership supervision
Country risk
This guide is updated each time a new article in the series is published.
