Checklist · Onboarding Governance
PEP Screening: A Review Record for a Potential Match
Review a potential PEP match through identity, public-role evidence, risk assessment and authorized decisions, without equating status with wrongdoing.
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Published by FxTrusts, a supplier of brokerage and prop firm technology. Prepared with AI-assisted research and drafting; reviewed against the cited public sources. Examples are illustrative. Product links describe our services.
Quick answer
A potential PEP match is a prompt to review identity and public-role information, not a finding of misconduct. Establish whether the record concerns the applicant or relevant owner, determine the role and applicable classification, then document the required risk assessment, approval and monitoring decisions under the operator's policy.
Separate the match from the classification
Record the screening provider, search inputs, source record, date, matched fields and available identifiers. Compare names with other relevant evidence such as birth information, public role and service dates. Preserve alternative explanations and missing information. A similar name should remain a possible match until the authorized process supports a conclusion.
If identity is established, record the actual prominent function and its context. FATF distinguishes foreign, domestic and international-organization PEPs and related persons, with different risk-based treatment described in its standards. Do not infer the category solely from the person's nationality or from the label used by one data vendor.
Sources for this section
- FATF PEP guidance: source of wealth and source of fundswww.fatf-gafi.org
- The FATF Recommendationswww.fatf-gafi.org
Document the risk assessment without stigma
FATF states that PEP measures are preventive and that the status should not be interpreted as criminal involvement. Keep that distinction visible in the case record and customer communication. A verified public role is a relevant fact; an allegation, sanction and criminal finding are different facts requiring their own evidence and process.
Assess the relationship under the applicable rules and policy, including the evidence needed for its purpose, funding context and any enhanced measures. A commercial screening database can supply useful information but is not a complete compliance process. Record what was checked, what remains uncertain and who may approve the next step.
Sources for this section
- FATF guidance: politically exposed personswww.fatf-gafi.org
Preserve decisions and review triggers
Use separate fields for identity-match result, PEP classification, risk assessment, approval status and monitoring plan. This avoids a single red or green label concealing several different decisions. Where additional approval is required, record the authority and the evidence considered; do not treat an automated provider result as that approval.
Review relevant changes in role, ownership, relationship activity or evidence. Do not invent a universal period after which a former PEP stops requiring consideration. Record the policy version and applicable basis for any change in treatment. Retain only the personal data needed for the review and restrict access to sensitive supporting material.
Example: role evidence confirms identity but not a final decision
A fictional applicant has the same full name and birth date as a listed former senior public official. Official role information supports the identity match, but the source-of-funds review is incomplete. The case record marks identity confirmed, role evidence reviewed and the business decision pending. It does not label the person criminal or automatically approve the account.
| Decision layer | Recorded evidence |
|---|---|
| Identity | Matched identifiers and unresolved discrepancies |
| Role | Function, jurisdiction, dates and source |
| Assessment | Relevant relationship facts and policy version |
| Approval | Authorized reviewer and decision rationale |
| Ongoing review | Triggers, owner and required follow-up |
Implementation checklist
- Preserve the original potential match and its source record.
- Verify identity and public-role context separately.
- Keep PEP status distinct from allegations or wrongdoing.
- Record required approvals and monitoring without universal expiry assumptions.
Sources
These documents support the reference. Check the original publication for current requirements and the limits of its scope.
- FATF PEP guidance: source of wealth and source of fundswww.fatf-gafi.org
- FATF guidance: politically exposed personswww.fatf-gafi.org
- The FATF Recommendationswww.fatf-gafi.org
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