How to start continuous control monitoring in a bank
Continuous control monitoring tests key controls automatically from system data rather than annual samples. Start with ten high-value, data-rich controls such as user access, payment limits and reconciliations; define the test and threshold for each; automate the data pull; route exceptions to owners with deadlines; and report results to the risk committee. Keep periodic testing for controls that cannot be automated.
When processes run at machine speed, including AI agents, annual testing finds problems months too late. Continuous monitoring closes that gap for the controls that matter most.
Five steps
Pick ten controls
Choose key controls with reliable system data and high loss potential.
Define tests
Write the rule, population and threshold for each control.
Automate data
Schedule extracts from source systems; avoid manual spreadsheets.
Route exceptions
Send breaches to named owners with due dates and track closure.
Report
Show exception trends and overdue items to the risk committee monthly.
Which controls are good candidates?
- Privileged and dormant user access.
- Payment and limit overrides.
- Segregation of duties conflicts.
- Reconciliation breaks and ageing.
- AI model performance thresholds and drift.
- Agent actions above limits or outside mandates.
Primary sources (reviewed 17 Oct 2026)
This page explains supervisory guidance in plain language. It is not legal advice; confirm how each text applies to your institution and jurisdiction.
Frequently asked questions
Does continuous monitoring replace internal audit?
No. It strengthens first- and second-line assurance; internal audit still evaluates whether the monitoring itself is designed and operating well.
Put these controls to work this month
Start on the cloud risk management software within 24 hours, or ask for training or advice tailored to your institution.