Politically Exposed Persons Screening

A politically exposed person (“PEP”) is an individual who is or has been entrusted with a prominent function by a local, regional, national or international governmental body. Given the global mobility of PEPs, the ComplyAdvantage database covers high-ranking government officials in every active jurisdiction. ComplyAdvantage provides a comprehensive and widely-adopted source of structured intelligence on PEPs and heightened risk individuals and organisations.

ComplyAdvantage aligns its PEP definition and categorization with the guidelines provided by the Financial Action Task Force (“FATF”). FATF is an inter-governmental body established in 1989 by the Ministers of its member jurisdictions.

The FATF currently comprises 37 member jurisdictions and 2 regional organisations, representing most major financial centres in all parts of the globe. The objectives of the FATF are to set standards and promote effective implementation of legal, regulatory and operational measures for combating money laundering, terrorist financing and other related threats to the integrity of the international financial system.

Because of the risks associated with PEPs, the FATF Recommendations require the application of additional AML/CFT measures to business relationships with PEPs. These requirements are preventive (not criminal) in nature, and should not be interpreted as meaning that all PEPs are involved in criminal activity, or even necessarily pose a high risk of money laundering. Further legislation around the world, including the EU’s 4th money laundering directive, mandates enhanced due diligence requirements when dealing with all politically exposed persons.

The ComplyAdvantage PEP Definition and ranking is based on the FATF version:

PEP CLASS 1

• Heads of state
• Members of the national executive
• Members of the national legislatures
• Senior officials of military and law enforcement
• Senior officials of national agencies
• Board members of central banks
• Senior judiciary officials (national level)
• Top-ranking officials of political parties

PEP CLASS 2 

• Board members of International Organizations (HIOs) & International Sports Federations
• Ambassadors,  high commissioners and other top diplomatic positions
• Members of the regional executive
• Members of the regional legislatures
• Senior judiciary officials (regional level)

PEP CLASS 3 

Senior management and board of directors of state owned businesses and organisations

PEP CLASS 4 

Mayors and members of local government (sub-regional level)

As several regulations and best practice guidelines include as PEPs not only the entities that currently hold relevant positions, but also entities that have stepped out of office, ComplyAdvantage also takes a similar approach. Therefore, the ComplyAdvantage database also includes as PEPs entities that have held one of the above positions, but do not hold one anymore. 

In addition, family members and close associates of PEPs are considered PEPs, and can be risk-ranked as described below.

Yes. The FATF recommendations apply also to relatives and close associates of prominent entities, as these are also viewed as a potential source of risk – given their connections with the PEPs.

ComplyAdvantage considers the following categories of family members relevant from a PEP screening perspective (but not limited to):

• Spouse/ partner (including a person who is considered by his national law as equivalent to a spouse)
• Siblings/ Half-siblings
• Children/ Step-children and their spouses and partners
• Parents/ Step-parents

If an entity belongs to any of the above categories, it will be ranked at the same level as the PEP associated with, unless the family member in question is a PEP in his/her own right. In such cases, the political position held by the spouse will determine his or her classification.

We cover the countries based on ISO 3166: https://www.iso.org/iso-3166-country-codes.html

We have a base coverage for all the countries listed there, but that doesn’t mean we have full coverage for all of them.

As our database needs to comply with many screening requirements across the world – as a general rule of thumb, we take the path of the most restrictive legislation. In this case, as some jurisdiction’s regulators require former PEPs to be screened, we will always flag a former office holder as a PEP irrespective of the time that person has exited office. This behaviour is true for all the new sources of data that we currently add and maintain in our database.

However, even if we take this most restrictive approach – we currently label all former office holders’ profiles with a “Remove date” that should serve as a proxy date for when the entity has exited office.

Yes, advance your customer screening with powerful, flexible “fuzzy matching” search capability that allows you to optimise for the reduction of false-positives in-line with your risk based approach. Our search algorithm accounts for all the major sources of mismatch in the name screening industry, such as name derivatives, phonetically similar names, spelling & typos, fuzzy matching and different name forms. 

All PEP Profiles are checked for updates daily.