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Ongoing Monitoring (Continuous Merchant Monitoring)

Ongoing monitoring also known as continuous merchant monitoring is the practice of regularly reviewing a merchant’s activity, behavior, and business profile after onboarding. It ensures that merchants continue to comply with card network rules, legal requirements, and the acquirer’s internal risk policies throughout the entire lifecycle of the merchant account.

Unlike onboarding, which offers a snapshot of the merchant at a single point in time, ongoing monitoring provides a dynamic, real-time view of risk. Merchants may evolve- adding new product lines, changing ownership, or experiencing shifts in transaction volume and these changes can introduce new compliance obligations or increased risk exposure.

Key Components of Ongoing Monitoring:

  • Periodic reviews of merchant risk profiles, including financial statements and chargeback ratios
  • Continuous transaction monitoring to detect fraud spikes, laundering, or operational anomalies
  • Website and content monitoring to identify prohibited goods or unauthorized changes in offerings
  • KYC/KYB refreshes when ownership, control, or business structure changes
  • Negative news and adverse media checks to flag reputational or legal risks



Why It Matters:

  • Regulatory compliance: Ongoing due diligence is required under many AML and payment regulations
  • Risk management: A merchant deemed low-risk at onboarding could later engage in high-risk activity (e.g., adding age-restricted or unlicensed products without disclosing the change)
  • Operational safeguards: Early detection allows acquirers to adjust terms such as raising reserves, reducing limits, or re-underwriting to mitigate exposure



For example, a merchant that begins as a low-risk apparel seller might, over time, introduce regulated products like vaping devices or CBD without prior approval. Through continuous monitoring, these changes can be flagged for review, ensuring that corrective actions are taken before violations or fines occur.

In essence, ongoing monitoring is about maintaining vigilance after onboarding, ensuring merchants remain compliant, aligned with their original business purpose, and appropriately classified in terms of risk. It’s a foundational element of any effective merchant risk management framework.

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