The Ultimate PEP Screening Checklist for Your Business

Last Updated: 

February 25, 2025

Corruption is a serious problem across the globe. If you’re running an online business, you’ll need to pay attention to the history of your customers. Politically exposed persons, or PEPs, can use online businesses to launder money and conduct illegal activities. 

While many entrepreneurs can say that their business is too small to be targeted, there’s always a certain amount of risk. PEP screening helps businesses recognise problematic customers and handle them according to the law. 

This article delves into the complexities of high-profile figures and the process of recognising, handling, and monitoring them. 

Key Takeaways on PEP Screening for Your Business

  1. PEP screening is essential for compliance: Businesses must conduct PEP checks to comply with regulations and avoid legal repercussions.
  2. Identifying high-risk individuals prevents exploitation: Recognising PEPs helps online businesses avoid being used for money laundering or illicit activities.
  3. Automated AML tools improve screening efficiency: Using technology-driven solutions speeds up customer verification and reduces manual errors.
  4. Adverse media monitoring enhances risk assessment: Checking news sources and online mentions can uncover crucial information about a PEP’s history.
  5. Ongoing monitoring is crucial for risk management: Continuous tracking of high-risk customers ensures timely detection of suspicious activity.
  6. Sanctions compliance is mandatory: Businesses must verify individuals against global sanctions lists to avoid legal and financial penalties.
  7. Different PEP classifications require tailored screening: Domestic, foreign, and sanctioned PEPs pose varying risks and must be handled accordingly.
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Why implement PEP screening? 

It’s obvious why you wouldn’t want someone potentially involved in criminal activities to be your customer. The reason why you should screen your customers whether they’re politically exposed personas is that there’s a greater risk that they’re involved in illegal activities.

PEP screening is a required part of know-your-customer verification, and failing to do this means that you won’t be compliant. This can lead to the termination of your business, fines, penalties, and reputational blows. 

In short, you must implement PEP monitoring because you might be breaking the law without it. However, even if the lack of this process is alright with the law, it’s still important to prevent your platform from being exploited by wrongdoers. 

Identifying PEPs can allow you to understand whether they have been involved in serious crimes, like money laundering or financing terrorism. If the answer is yes, you can then easily forbid them from using your platform.

On the other hand, if they are a PEP and they haven’t caused serious problems, you can allow them to use the platform, but monitor them more closely. 

Overall, if your business happens to be victim of money-laundering activities, you can lose customer trust and integrity, which is why the implementation of PEP screening is essential. 

PEP Checklist

To make sure that you’ve conducted your screening properly, we’ve created a concise checklist that will help you guide your process: 

  1. Identification of PEP status: Start by determining whether your customer is a current or former PEP and identifying their role. If a customer isn’t in this category, check whether they’re associated with such individuals. 
  2. Sources for PEP screening: The most important sources for checking whether an individual is politically affiliated are government databases and records. Besides that, there are global lists specialised for these individuals. Eventually, you can check the relevant media sources.
  3. Risk assessment factors: There are multiple levels of risks depending on the individual’s background. You need to check the importance of the position a person holds, their sector, and the amount of influence they have. 
  4. Enhanced Due Diligence (EDD): Gather additional information on them, such as nationality, ID, and education. Using relevant sources, assess their sources of wealth and funds. 
  5. Ongoing monitoring and review: Perform periodic reviews of PEP relationships, with frequency based on risk level. Furthermore, real-time transactions for risky individuals should be implemented. 
  6. Compliance and reporting obligations: Report suspicious transactions to Financial Intelligence Units (FIUs) if necessary. Regardless of the person, maintain detailed records of PEPs.

Role of technology in PEP checks 

With the latest innovations in the field of tech, identifying  has become easier and more streamlined. There are multiple methods that can help you recognise PEPs and report them to the relevant authorities. 

1. Automated screening with AML tools

A more advanced option for identifying high-risk individuals is through the use of AML tools. These tools are automated and can compare millions of new customers for short periods. 

You can use PEP screening tools by integrating them on-premise or via an API. Of course, this method isn’t perfect, either. This software leverages algorithms that can flag individuals as false negatives and false positives. 

Besides the speed, automated AML tools can be integrated and can continue with screening in real-time. You can receive automated and instant updates and alerts. AML tools automatically flag the risk that a customer poses based on their location and affiliations. 

With the rise of artificial intelligence and machine learning, AML tools are becoming better at identifying suspicious transactions and customer activity. 

2.  Adverse Media Monitoring

Through using technology-driven solutions, you can scrape the internet for any mentions of the individual you’re verifying. This is important as it can unveil important information that can help you identify whether an individual is a PEP.

Global and local news sources can provide you with information on the individual’s arrests, cases, involvement with criminals, and other suspicious activities. This technology can better help you assess the risk an individual poses. 

3. Integrated sanctions technology

Instead of using dozens of tools that specialise in doing one task, integrated sanctions technology provides you with a centralised place for the screening process. It aggregates information from news, blacklists, and other sources.

This type of software can significantly streamline the process of recognising PEPs, as you won’t have to manually check different sources, and use multiple tools. 

4. Electronic Identity Verification

Manually analysing vast amounts of customers is time and resource-consuming. Checking ID cards of customers can be streamlined with the use of software. This allows businesses to accurately verify the identities of their customers. 

Furthermore, this software also comes with features that allow real-time updates if an individual’s status changes. This also means that it’s updated with the latest information from relevant global sources on politically exposed personas. 

Types of PEPs

Politically exposed persons can come from different locations. Although there are more ways in which we can categorise them, their country is important as it has additional implications in terms of how they should be handled. 

Different countries have different classifications and regulations for politically exposed personas. Ensuring that these individuals aren’t causing harm is an international effort, and it’s essential to check them against sources from multiple countries and regions. 

Domestic 

Pretty self-explanatory, domestic politically exposed persons are individuals who hold prominent positions in the country where your business is located. These can include the head of the state, senators, senior politicians, high-ranking military officers, political party officials, etc. 

This type of high-risk person is easier to conduct a background search on, as you’ll have access to the necessary documentation from the local government and agencies. Furthermore, they’re more easily recognised, as it’s likely that they’re mentioned on the local news. 

In countries that have a higher corruption index, weak institutions, or an autocratic regime, the risk that PEP poses is higher. 

For example, the European Union explains requirements through the 4th AML Directive and 6th AML Directive. These directives explain that mandatory identification is required, and how these individuals are defined. 

Foreign

Similarly to domestic PEPs, foreign are individuals who hold notable positions in countries other than the one your business is based in. A strong reason why someone from a foreign country needs to be screened is because they might be involved in criminal activities there.

For example, they don’t have the means to conduct illegal business in their home country, so they opt for online businesses elsewhere. Different jurisdictions have different levels of transparency and laws. 

Foreign PEPs can also be located in the country like your business, and they can be ambassadors or immigrants. A foreign ambassador can have some privileges, allowing them to conduct money laundering or other illicit activities. 

PEPs from sanctioned countries

Countries can be sanctioned for multiple reasons. They can use online businesses to smuggle funds, just like foreign PEPs. These individuals require additional screening, especially to ensure compliance with sanctions imposed by organisations like the United Nations (UN), the European Union (EU), and the Office of Foreign Assets Control (OFAC).

Furthermore, it’s essential to check whether someone is sanctioned individually, even if their country isn’t. These individuals are often sanctioned for international crime. 

Identifying high-risk individuals is essential for businesses.

Online businesses, especially the ones in the iGaming and fintech businesses, provide customers with a plethora of advantages. However, these businesses are also at high risk of being exploited by criminals and hackers. 

PEP screening ensures that if a suspicious individual creates an account on your platform, you’ll be able to recognise it on time and take action. Failing to achieve this can lead to serious problems with the law and even to bankruptcy.

Regardless of your traffic and industry, it’s crucial that you conduct proper screening through the methods mentioned below to minimise the chances of becoming a victim of fraud or money laundering. 

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