Continuous surveillance: the judgment moves the moment the facts do
Onboarding is not the end of diligence — it is the start of a watch. Every existing client can drift out of alignment with the institution: executive fraud, indictments, litigation, regulatory enforcement, sanctions exposure. Those events become reputational, legal or financial liabilities, and they are too often discovered from the newspaper rather than the file.
How the watch works
- Detect. Court dockets, regulators, sanctions lists, corporate registries and global media are swept on a continuous cycle and matched against the monitored book.
- Resolve. Entity resolution confirms that the match is the client or a party within the client's ownership or association graph, with a confidence score attached.
- Re-score. The profile is recalculated and the delta is explained: what changed, by how much, and on the strength of which citation.
- Escalate. A recommended posture is issued — retain, restructure, restrict, or exit — with the full evidentiary trail behind it.
Worked escalations
- Client N-4410 is named a relief defendant in a civil forfeiture action: risk moves 48 to 74, posture restrict.
- Client N-0917 acquires second-hop sanctions exposure through a holding chain: risk moves 35 to 51, posture watch.
- Client N-1188 has a regulatory inquiry closed with no action: risk moves 46 down to 31, posture retain.
Scores move in both directions. A closed inquiry is as much a fact as an opened one, and the record reflects it.
What the regulator sees
Every re-score, every source, every model version and every human override is written to an append-only audit trail with a content hash, and can be exported for examination. See security and governance.
Frequently asked questions
- How often are existing clients re-scored?
- Daily on the Desk plan and intraday on the Institution plan. A profile is also re-scored immediately when a matched high-severity event lands, such as a sanctions designation or an unsealed indictment.
- What counts as an escalation event?
- Court filings and dockets, unsealed indictments, regulatory enforcement, sanctions and PEP designations including 50-percent-rule exposure through ownership chains, insolvency and forfeiture actions, and tier-weighted adverse media storylines.
- What does the desk actually receive?
- A delta: the previous score, the new score, the specific event that caused the move, the citation and retrieval date, and a recommended posture — retain, restructure, restrict, or exit.
- Does surveillance cover people one hop away from the client?
- Yes. Network exposure is resolved through ownership graphs and association mapping, so an indictment naming an associate one hop from a monitored client raises that client's score with the connection made explicit.