Which of the following best describes 'ongoing member due diligence' under the BSA/AML compliance program?

Ongoing member due diligence is an essential component of a Bank Secrecy Act (BSA) and Anti-Money Laundering (AML) compliance program. It refers to the continuous assessment of a customer’s risk profile, including monitoring their activity and behaviors over time. This approach ensures that financial institutions remain aware of any changes in a member's risk level and can adapt their monitoring and compliance efforts accordingly.

The identification of risk is not a one-time task; it evolves as member relationships change and as new information becomes available. Periodic assessments allow institutions to spot unusual patterns or discrepancies that could indicate suspicious behavior, enabling them to respond effectively to risks as they arise.

This method stands in contrast to conducting a single review or only reacting when large transactions occur, which would not adequately capture the dynamic nature of member activities and associated risks. Similarly, immediate reviews upon account opening would not account for ongoing changes in risk that could develop over time. Therefore, the emphasis on periodic assessment of member risk and behaviors accurately encapsulates the concept of ongoing member due diligence within a robust BSA/AML compliance framework.