Curious - For those that "manually" monitor those deemed High Risk @ account opening, how often do you monitor those? Your criteria? Do you change the "risk score" and where?

Please define "manual" monitoring.

Using a spreadsheet to keep track of those deemed high risk.

We have a spreadsheet for cash intensive, PATMO's, MSB's etc. they are subject an annual review at minimum and our spreadsheet lists date of last on-site visit, last activity review, etc. I do have a form (shared it in the banker tools) that I document the annual review. Used to be in paper form but working on uploading the documentation to our AML system.

Quarterly