# AMLR Art. 26 — Ongoing monitoring > AMLA's guidelines on ongoing monitoring are due by 10 July 2026 (Art. 26(5)), a year ahead of AMLR's general application date of 10 July 2027. The adviser regime, which has no ongoing-monitoring duty, has been in force since 1 October 2026. See [[Effective-dates timeline]]. - **Part of:** [[AMLR]] - **FATF keying:** [[FATF R.10 - Customer due diligence|FATF R.10]] - **Swiss provisions:** [[GwG Art. 6 - Special due diligence obligations (clarification|GwG Art. 6]], [[GwV-FINMA Art. 20 - Monitoring business relationships and transactions|GwV-FINMA Art. 20]] - **Detailed citation:** GwG Art. 6; GwV-FINMA Art. 20 > [!tip] In practice > - Swiss law scales the review frequency to risk, with no fixed maximum. The AMLR requires updates at least every year for higher-risk customers and every five years for all others. > - Banks and securities firms must run an IT-based transaction-monitoring system (GwV-FINMA Art. 20). The AMLR prescribes no system. > - Advisers under the 2025 GwG revision have no ongoing-monitoring duty. ## What it requires AMLR Art. 26 requires ongoing monitoring of business relationships and of customer transactions, checked against the entity's knowledge of the customer, its business activity and risk profile, and, where needed, fund origin and destination. Customer information must be kept current, updated at least every 1 year for higher-risk customers subject to enhanced due diligence and every 5 years for all others, plus ad hoc whenever circumstances change, a legal review duty arises, or a relevant new fact emerges. Entities must also regularly re-verify targeted-financial-sanctions screening. ## Swiss position GwG Art. 6 Abs. 1 requires identifying the type and purpose of the relationship, scaling the scope of information, the decision-making hierarchy, and the periodicity of controls to the risk the contracting party presents. GwV-FINMA Art. 20 Abs. 1 requires effective monitoring of relationships and transactions so increased risks are identified. Abs. 2 obliges banks and securities firms specifically to run an IT-based system helping identify increased-risk transactions under Art. 14; Abs. 3 requires flagged transactions to be evaluated within a reasonable time, with further clarification under Art. 15 where needed. Abs. 4 lets banks/securities firms with few contracting parties, beneficial owners or transactions forgo that system; Abs. 5 lets FINMA require one from the other intermediaries it lists (e.g. insurers, fund managers, fintech-licence firms, portfolio managers) where needed. ## Key divergences Neither GwG Art. 6 nor GwV-FINMA Art. 20 states AMLR Art. 26(2)'s fixed review ceilings - 1 year for higher-risk customers, 5 years for others; Swiss law scales periodicity to risk without a stated maximum. GwV-FINMA Art. 20 mandates an IT-based monitoring system for banks and securities firms specifically, and GwV-FINMA Art. 73 extends a system duty to money and value transfer businesses, deeming any linked transaction reaching CHF 5,000 increased-risk; AMLR Art. 26 requires effective monitoring but prescribes no system. GwV-FINMA Art. 72 exempts portfolio managers and trustees with up to 20 permanent relationships from setting criteria for higher-risk relationships, a de-minimis carve-out AMLR Art. 26 has no counterpart for. GwG Art. 6's monitoring duty does not extend to advisers under the 2025 revision, who owe no ongoing-monitoring or re-identification duty - see [[The adviser regime (2025 GwG revision)]]. ## Effective dates AMLA's guidelines on ongoing monitoring are due by 10 July 2026 (Art. 26(5)), a year ahead of AMLR's general application date of 10 July 2027. The adviser regime, which has no ongoing-monitoring duty, has been in force since 1 October 2026. See [[Effective-dates timeline]]. ## Further connections *These links come from an article-by-article comparison of the primary texts. They add to the provisions listed at the top of this note and make no equivalence claim.* - [[GwG Art. 7 - Duty to keep records|GwG Art. 7]] — GwG Art. 7 Abs. 1bis requires periodic risk-based review and updating of records; AMLR Art. 26(2) additionally sets maximum update intervals of 1 year (higher risk) and 5 years. *(direct)* - [[GwV-FINMA Art. 14 - Higher-risk transactions|GwV-FINMA Art. 14]] — GwV-FINMA Art. 14 requires financial intermediaries to develop criteria for recognising higher-risk transactions; suggested criteria include significant deviations from the usual transaction types, volumes and frequencies of the relationship (Abs. 2 lit. b, c). The monitoring itself is GwV-FINMA Art. 20; AMLR Art. 26(1) requires monitoring against knowledge of the customer. *(related)* - [[VSB 20 Art. 46 - Repetition in case of doubt|VSB 20 Art. 46]] — VSB Art. 46 Abs. 1 requires repeating controlling-person and beneficial-owner establishment when doubts arise whether they remain the same and the doubts cannot be dispelled by clarification, an event-driven refresh; AMLR Art. 26(3) triggers on any change of circumstances or relevant fact, not only doubt. *(related)* ## Authoritative text > [!quote]- Regulation (EU) 2024/1624 (AMLR), Article 26 — English text (EUR-Lex, CELEX 32024R1624) > **Article 26** > *Ongoing monitoring of the business relationship and monitoring of transactions performed by customers* > 1. Obliged entities shall conduct ongoing monitoring of business relationships, including transactions undertaken by the customer throughout the course of a business relationship, to ensure that those transactions are consistent with the obliged entity’s knowledge of the customer, the customer’s business activity and risk profile, and where necessary, with the information about the origin and destination of the funds and to detect those transactions that shall be made subject to a more thorough assessment pursuant to Article 69(2). > Where business relationships cover more than one product or service, obliged entities shall ensure that the customer due diligence measures cover all those products and services. > Where obliged entities belonging to a group have business relationships with customers that are also the customers of other entities within that group, whether obliged entities or undertakings not subject to AML/CFT requirements, they shall take into account information relating to those other business relationships for the purposes of monitoring the business relationship with their customers. > 2. In the context of the ongoing monitoring referred to in paragraph 1, obliged entities shall ensure that the relevant documents, data or information of the customer are kept up to date. > The period between updates of customer information pursuant to the first subparagraph shall be dependent on the risk posed by the business relationship and shall not in any case exceed: > (a) for higher risk customers to which measures under Section 4 of this Chapter apply, 1 year; > (b) for all other customers, 5 years. > 3. In addition to the requirements set out in paragraph 2, obliged entities shall review and, where relevant, update the customer information where: > (a) there is a change in the relevant circumstances of a customer; > (b) the obliged entity has a legal obligation in the course of the relevant calendar year to contact the customer for the purpose of reviewing any relevant information relating to the beneficial owners or to comply with Council Directive 2011/16/EU (42); > (c) they become aware of a relevant fact which pertains to the customer. > 4. In addition to the ongoing monitoring referred to in paragraph 1 of this Article, obliged entities shall regularly verify whether the conditions laid down in Article 20(1), point (d), are met. The frequency of that verification shall be commensurate with the exposure of the obliged entity and the business relationship to risks of non-implementation and evasion of targeted financial sanctions. > For credit institutions and financial institutions, the verification referred to in the first subparagraph shall also be carried out upon any new designation in relation to targeted financial sanctions. > The requirements of this paragraph shall not replace the obligation to apply targeted financial sanctions or stricter requirements under other Union legal acts or under national law on the verification of the client base against lists of targeted financial sanctions. > 5. By 10 July 2026, AMLA shall issue guidelines on ongoing monitoring of a business relationship and on the monitoring of the transactions carried out in the context of such relationship. ## Sources - AMLR Art. 26 — CELEX 32024R1624 - GwG SR 955.0, Art. 6 - GwV-FINMA SR 955.033.0, Art. 20 - GwV-FINMA SR 955.033.0, Art. 72 - GwV-FINMA SR 955.033.0, Art. 73