Risk-Based KYB Monitoring: Meeting Regulatory Expectations in Asia

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A single KYB check once a year might have sufficed a decade ago, but in the Asia-Pacific region, regulators now expect firms to review their counterparties at intervals that reflect their risk level. They want to see that changes in ownership, sanctions exposure, or reputation are identified promptly, rather than months later.  

The Monetary Authority of Singapore makes this clear in Notice 626 (PDF, 28 March 2024), describing ongoing monitoring as a central part of AML and CFT due diligence. In other words, monitoring isn’t just a regulatory box to tick. It’s part of how firms prove they understand and can manage risk.

Why traditional KYB reviews miss the mark

Periodic reviews only give you a snapshot in time. In Asia’s fast-changing markets, that picture goes out of date quickly. 

Ownership structures change. Directors depart. Nominee shareholders emerge. Dormant companies reawaken. Each shift subtly alters the risk profile.  

The region’s interconnected trade adds another layer. In 2023, intra-ASEAN trade was valued at US$769.9bn, meaning a compliance failure in one market can ripple across others. 

And risk extends beyond registry data. Sanctions and reputational issues evolve faster than paperwork can keep up. The U.S. Treasury’s OFAC issued $1.54 billion in 2023, many due to gaps in monitoring. A sanctioned UBO today can jeopardise a business partner tomorrow, and one damaging media story can undo months of due diligence.

Regulators are losing patience

Recent enforcement clearly shows that firms are being fined not for bad onboarding, but for what happens afterwards.

These were not onboarding failures. They were monitoring failures, where the risk drifted, and the systems failed to catch up.

What Regulators Now Expect

The direction across the region remains consistent, as monitoring must be risk-based, structured, and responsive.

  • FATF (Global): Recommendation 10 incorporates ongoing monitoring into due diligence, emphasising that firms should regularly review customer information in relation to risk.
  • MAS (Singapore):  Notice 626 (2024) mandates that financial institutions identify material changes in customer risk promptly, rather than just annually.
  • HKMA (Hong Kong): Considers weak monitoring as a breach in itself.
  • AUSTRAC (Australia): Requires firms to align monitoring frequency with customer risk levels and penalises those that fail to do so.

Regulators increasingly stress that the value of monitoring lies in its accuracy and relevance. The real goal is to keep information reliable between reviews making sure material changes are identified and addressed before they create risk exposure.

How Leading Firms Are Adapting

Leading compliance teams are modernising how they run their periodic checks. They are keeping the regulatory structure but making it smarter. 

High-risk entities, politically exposed directors, complex UBO structures, and sanction-sensitive industries get reviewed more often. Lower-risk ones move to longer cycles. 

Many now pair these schedules with event-based triggers. If a director changes or adverse media appears, the system kicks off a recheck automatically. That way, firms aren’t waiting for the next calendar review to catch something important. 

In markets like Indonesia, Vietnam and Thailand, fragmented registries and multiple languages make this even trickier. That’s why firms are turning to platforms that pull together registry, AML and media data in one place helping them focus on what’s actually changed.

What Good KYB Monitoring Looks Like

Regulators are not impressed by how often you check. They care about what you do with what you find. 

Strong frameworks have four things in common:

  • Coverage: registry, legal and sanctions data across jurisdictions and languages.
  • Cadence: automated, risk-based review schedules with clear service levels.
  • Escalation: set workflows from detection to resolution.
  • Evidence: audit trails showing how alerts were handled.

That combination separates “monitoring on paper” from monitoring that actually works.

The Strategic Upside 

Smarter periodic monitoring isn’t just about staying compliant. It helps firms spot trouble early, cut manual workload, and build confidence with regulators and partners.  

According to McKinsey, effective risk transformation programmes including improved monitoring can cut costs by 15–25 % while maintaining or improving effectiveness. Fewer false positives, faster reviews, less remediation and stronger resilience overall.

Automated, Risk-based Monitoring with AsiaVerify

AsiaVerify helps firms meet these expectations through automated, risk-based periodic monitoring. Clients can choose how often to re-check a company either monthly, quarterly, half-yearly or yearly depending on its risk profile. 

Each time a company is re-monitored, the system highlights exactly what’s changed since the previous report.
For example:

  • Director change from Mr A to Mr B (effective 10 Nov 2025)
  • Address change from 123 Street to 456 Lane (effective 15 Dec 2025)

This approach gives compliance teams a clear view of what matters, without repetitive manual review. It supports compliance audits, remediation projects and M&A due diligence, and is being customised country by country, starting with China, to reflect local regulations and improve client adoption. 

 

 

To find out more or to enable monitoring for your portfolio, book a demo today.

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