What is Trigger-Based Review?
The short answer
Trigger-based review starts a reassessment when a defined event or change warrants attention.
Trigger-Based Review: why it matters
An onboarding or review decision can contain several different questions. Keeping this concept distinct helps the team assign the right evidence and decision owner, rather than rely on a single completed status.
How to assess it in practice
Connect a meaningful event, such as a documented ownership change, to an accountable review workflow. Start by defining the question the team needs to answer. Identify the relevant record or evidence, check its scope and date, and retain the reasoning behind the result. If evidence conflicts, keep that conflict visible for review.
Worked example
Illustrative workflow: a team reviewing a business adds a separate check for trigger-based review. The reviewer’s task is to connect a meaningful event, such as a documented ownership change, to an accountable review workflow. The outcome is recorded together with the supporting evidence; an unresolved question stays open rather than being converted into a positive result.
A change of control triggers a targeted ownership review, while a minor formatting change to an address is logged without automatically repeating the entire onboarding process.
Distinctions that matter
Trigger-Based Review belongs to the ongoing review & funding context topic family. Read Ongoing Due Diligence alongside it to understand the adjacent question. Each page has its own intended scope; shared context does not make the concepts equivalent.
Evidence and review output
Review these
- Previously approved baseline
- New facts and source dates
- Review outcome and next trigger
The review should produce
An updated relationship assessment with changes, unanswered questions and the next action made explicit.
Across this family
Compare the current understanding of a relationship with its approved baseline. A scheduled review and an event-driven review can answer different questions, so specify what triggers each and how outcomes update the file. A delivered notification is not itself a completed reassessment.
A note from practice
A useful trigger has a specified event, affected relationship and expected action. Too many low-value alerts can overwhelm reviewers; too few can leave material changes outside the reassessment workflow.
Limits and common mistakes
The practical boundary is important: Connect a meaningful event, such as a documented ownership change, to an accountable review workflow. Do not substitute a related label for this check or assume that missing information is a negative finding. Source-specific and jurisdiction-specific rules require their own review.
Frequently asked questions
Which evidence should I review?
How is Trigger-Based Review different from Source of Funds?
What should the result of the review contain?
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Related topics
- Ongoing review & funding contextOngoing Due DiligenceOngoing due diligence maintains an understanding of an existing relationship as customer information and activity change.
- Ongoing review & funding contextPeriodic ReviewPeriodic review reassesses a relationship on a defined schedule using relevant current information.
- Ongoing review & funding contextSource of FundsSource of funds concerns where the money used for a particular transaction or relationship comes from.
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