A common question concerns the frequency of checks of the customer base. Art. 9 (duty to report) of the Anti-Money Laundering Act (AMLA) is relevant to this question: a financial intermediary must immediately file a report with the Money Laundering Reporting Office Switzerland (MROS) as defined. It is evident that immediate reporting is difficult if the customer base is checked infrequently.

From a practical standpoint, intuition may tell us that the more frequent the checks, the more work must be spent on assessment of matches between customer data and profiles of sanctioned persons, PEPs, and others. However, whether this conclusion is correct or not, depends on the whitelisting.

A well-designed whitelisting algorithm avoids as much unnecessary assessment work as possible. For instance, if the customer data and matching profile, have not changed since the last assessment, then a reassessment may not make sense, since no new information is available. In addition to this very simple case, various other, more complex situations exist, where a reassessment can be avoided.

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