Annual risk assessments are insufficient because they produce a point-in-time verdict in a system where risk changes continuously. A third-party provider can pass its annual review and have its risk profile change materially the next week – through an M&A event, a control failure, or a shift in how it handles data – with no mechanism to surface that change until the next scheduled cycle.
Most incidents surface in the gap between scheduled reviews, not during them. Supervision in open finance is periodic and jurisdiction-bounded by design – each regulator reviews its own part of the chain on its own schedule. Risk in the network itself is continuous and cross-sector. Real-time monitoring closes that gap by tracking a provider's risk profile as it changes, rather than only at the moment of assessment.
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