Trigger Events
- Counterparty not present in KYB or KYS registry.
- IBAN and name mismatch.
- Introduction of new banking coordinates.
- Transfer above predefined monetary threshold.
- Counterparty reaching 20 percent annual concentration.
- Case reaching 12-month expiry.
Triggers activate structured review.
Escalation Levels
- Level 1 - Review: reassessment of documentation, rationale, and exposure.
- Level 2 - Enhanced Due Diligence: expanded structural analysis and deeper verification.
- Level 3 - Decision Gate: temporary suspension until governance alignment is restored.
Escalation intensity aligns with monitoring tier and risk appetite.
Monitoring Context
Detection may occur during annual refresh, monthly monitoring, or in real time via API connectivity.