PEP screening: definition, practical steps and an example

What is PEP screening?

PEP screening checks whether a person is a politically exposed person: someone who holds, or has held, a prominent public function. It combines identity checks with evidence of the role, its jurisdiction and relevant dates. Depending on the applicable framework, the assessment also considers family members and close associates.

The purpose is to identify relationships that need further risk assessment and due diligence. FATF guidance distinguishes foreign, domestic and international-organisation PEPs. A PEP finding is not evidence of corruption, a criminal finding or a sanctions designation. The measures required depend on the applicable rules and circumstances.

How to perform and document a PEP check

Start with a defined scope and reliable identity information. A database flag is a lead to investigate; it does not explain a person’s role or complete the assessment. FATF notes that commercial databases alone are insufficient to meet its PEP requirements.

• Set the scope: identify the jurisdictions, roles, former roles and connected-person categories the review needs to cover.
• Compare identity: use the name and relevant distinguishing facts from verified intake. Record both agreements and conflicts; leave unavailable facts unknown.
• Verify the role: consult reliable role records, such as an official appointment notice, alongside any provider result. Distinguish appointment, departure and publication dates.
• Assess and record: retain the source references, identity reasoning, role period, unresolved questions and reviewer decision. Follow the applicable process for further due diligence and approval.
• Plan review: record when and why the assessment should be revisited, including changes of role or new evidence. Keep sanctions screening as a separate check.

Worked example: a name match with an unresolved identity

Synthetic example: an applicant named Alex Morgan matches a profile for a former deputy minister. An official appointment notice supports a public role from 2020 to 2023, but the profile has no birth date and the applicant’s identity has not been linked to it. A shared name is insufficient to conclude that the applicant held that role.

The reviewer records “possible match, identity unresolved,” cites the appointment notice and requests an appropriate distinguishing fact through the approved intake process. The role end date stays separate from the notice’s publication date; leaving office does not by itself settle how the applicable framework treats a former PEP. If the identity is confirmed, the reviewer assesses that role under the relevant policy. If reliable facts distinguish the people, the reviewer documents why the match was dismissed.

A sanctions no-match does not resolve this PEP question. Keep the outside assessment pending while required evidence is missing, and retain the final reasoning when the review is complete.

Record an outside PEP assessment in SanctionsKit

PEP screening looks for relevant prominent public roles and requires a check that it is the same person. SanctionsKit does not provide comprehensive PEP screening. Use its supported sources for your sanctions and watchlist check, with a separately evaluated process for the PEP coverage your policy needs.

Check coverage and GET /api/v1/sources before selecting sources. A country-specific public-office entry has its own limits. It does not establish coverage of every role, former officeholder, family member or associate. A sanctions no-match is not a PEP result.

Make the outside assessment a visible case task

An owner or administrator can add a PEP assessment under Required external checks in Screening policies in the dashboard. Name the approved external process and the facts about the person and role to review. Tell staff which evidence reference to retain.

Publish the policy and select it for screening. The check creates a task; it does not query a PEP database. Its completion record is required before the governed review can finish. A no-match can therefore still have an open case for this outside work.

Use the same customer identity in both processes

Submit facts you trust from intake through New screening or POST /api/v1/screenings. Choose approved available sanctions or other sources and the policy reference when required. Keep the same customer ID on the screening and outside PEP review so the two records belong to the right person.

Review each source candidate on its own evidence. A similar sanctions name and a similar public-role profile are two comparisons, not two votes for one identity. Unknown dates or IDs stay unknown. Do not merge unrelated people because their names agree.

Record what the external evidence supports

A permitted reviewer completes the task with an evidence reference or records not applicable with a reason allowed by policy. Keep the source, relevant role and dates, identity reasoning and remaining limits available to authorized reviewers.

Use an approved external document reference when the assessment is stored elsewhere. The link does not copy the original file. Keep sensitive evidence out of general notifications. Finding a public role is not evidence of a crime.

Finish each required decision without overstating coverage

Complete SanctionsKit candidate decisions, external checks, business action and any required independent approval. API clients can read the case but cannot mark a human assessment complete or approve it. Keep the original screening and outside PEP findings separate.

Use review documentation to connect those states. Test a PEP assessment still pending after a sanctions no-match. Where policy requires it, onboarding must remain pending. The AML guide shows where these checks fit the wider process.

Frequently asked questions