Summary

A politically exposed person (PEP) is a person, an immediate family member of that person, or someone who has closed business ties to that person, who is or has been (in the last 12 months) in a prominent public function. For example, a head of state, senior politician, or an official with a public profile. 

Under anti-money laundering regulations, the main aim of applying additional scrutiny to work involving PEPs is to mitigate the risk that the proceeds of bribery and corruption may be laundered, or assets otherwise stripped from their country of origin.  

Reporting entities must, as soon as practicable after establishing a business relationship (or occasional activity), take reasonable steps to determine if a customer or beneficial owner is a PEP. If they determine their customer or beneficial owner is a PEP, there are additional measures that need to be applied. 

First AML complete PEP checks on all individuals verified via the First AML Platform.

These checks are surfaced in the Verification Report to be presented with one of the following flags:

• Match = PEP match identified 
• Possible Match = not a clear positive or negative result 
• No Match = no PEP match identified

When a PEP check is run on an individual and returns back a positive result, they will be flagged in the First AML platform as a 'Match'. When an individual is flagged as a 'Match' it will also be detailed in the notes section for the compliance team to review:

Name: State what matches (e.g. first, middle, last name)

DOB: Match/No Match

Associated Country/Citizenship: Match/No Match

Photo: Match/No Match/None

Summary: add info around findings e.g. Positive PEP Match: Son of Boris Johnson (British politician serving as Prime Minister of the United Kingdom  and Leader of the Conservative Party since 2019).

In some cases there is not a clear positive or negative result returned and these individuals will be flagged as a "Possible Match" in the system, along with a brief note in the notes section. This information should then be further reviewed by your compliance team to determine the outcome.

If there are no positive results returned on an individuals PEP check, they will be flagged with "No Match" in the system.

TABLE OF CONTENTS

• Summary
• What this will look like in the First AML Platform
  • Individual Profile Tab
    • Individual Profile Tab - Notes
  • Individuals Tab
  • Review Section
    • PEP Match
    • Possible Match
    • No Match
  • Reporting

What this will look like in the First AML Platform

Individual Profile

Please see the bottom section for the PEP status. 

Status in the Individual Profile

Individual Profile - Notes

It is mandatory for the analyst to add in notes when the PEP check returns a "Match" or "Possible Match" result on an individual and this will be reflected in the First AML platform as below;

Notes when PEP is a Match - Individual Profile

Notes when PEP is a Possible Match. PEP Note is mandatory for Possible Match or Match - Individual Profile

Individuals Tab

You will see an orange flag colour to indicate a Possible PEP Match in the individuals tab from the main case page as shown below;

Case details - Individual tab

Review Section

You will also be able to view the PEP notes under each individuals profile when checking a case for approval using the peer review feature

PEP Match

PEP Note for Match displayed in Review List.

Possible Match

PEP Note for Possible Match displayed in Review List 

No Match

PEP Note for No Match displayed in Review List. 

Reporting

There is an option in the PEP status filter called “Possible Match” and "PEP Match" to allow easy filtering of the cases that are flagged with either status

Reporting - An option in PEP status filter