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Sanctions Search and PEP Screening

Our automated platform uniquely equips you to carry out sanction searches and checks for PEPs and RCAs. If our software finds a match for your client, we’ll filter out false positives, and alert you once the match has been confirmed.

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What is PEP and Sanction screening?

PEP and sanctions searches are part of the Customer Due Diligence (or KYC) process; individuals and businesses are identified and verified, and then their details are checked against sanction and PEP lists.

Why do we need to screen for Sanctions and PEPs?

It is illegal to work with anyone on a Sanctions list and while it is not illegal to work with PEPs, they pose a greater risk to businesses. Therefore, all companies need to know if a customer has been identified on a Sanctions list or as a PEP, so they can assess the legalities and/or risk of working with them.

What is RCA Screening?

RCA stands for Relatives and Close Associates, defined as any individuals or businesses that are either related to or closely associated with a PEP. It’s important to identify RCAs as they may be vulnerable to bribery, blackmail and corruption due to their relationship with someone in a position of authority and influence.

How do I monitor Politically Exposed Persons (PEPs)?

Lists of PEPs are publicly available, but there is no central source, so keeping records up to date manually is almost impossible. The best way to monitor PEPs is via an electronic AML platform with daily monitoring. SmartSearch uses the Dow Jones WatchList which has access to more than 1,100 PEPs and Sanctions lists and is updated daily.
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Bespoke packages to suit your business

We can create a tailor-made package to fit your needs and budget without compromising on functionality and service to ensure our unique AML solution is affordable to all businesses.

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PEP and Sanction screenings with TripleCheck: Unlock faster, more accurate and reliable results

Anti-money laundering (AML) compliance is an imperative duty for regulated firms, but the right technology and tools can help simplify the process.

We have developed an advanced AML Compliance product that will help you meet all AML regulations and requirements while significantly reducing the time you spend processing documents. By implementing our robust solution, your business will gain access to:

Real-time monitoring & alerts: 

You’ll benefit from real-time monitoring capabilities with automated alerts to notify your compliance team of any sanction or PEP changes daily. Any changes in individuals or entities will then trigger Enhanced Due Diligence, allowing institutions to take proactive measures in preventing potential threats.

Advanced risk analysis & reporting: 

Our software has advanced analytics capabilities, which allow you to map out transactions in order to determine risk scenarios and provide detailed reports outlining suspicious activity. This ensures your institution remains compliant with all relevant regulations regarding money laundering and transactional monitoring.

User-friendly interface:

Our user-friendly platform requires minimal training, delivering a modern and intuitive interface. What's more, our dedicated account managers are on hand to answer any questions and ensure you have the most cost-effective licence and service growth headroom.

In-house data hosting: 

We host The Dow Jones Factiva Watchlist database in-house, which offers a dependable data source featuring more than 1,100 international sanction and PEP lists that are refreshed daily. Regular monitoring services, as well as any necessary changes to comply with global regulations or local laws, are made easier through this screening process.

Are you eager to discover how your business can gain from our award-winning compliance and AML software?. Let one of our highly-trained sales team demonstrate the multi-award winning platform and build your bespoke solution today.

What are Sanctions and PEPs?

Sanctions are restrictions used to stop individuals and entities who are involved in – or suspected of – illegal activities from engaging in certain industries. Government bodies and financial authorities both issue sanctions lists; these can be used to screen individuals and organisations for financial sanctions.

A PEP, or Politically Exposed Person, is someone who holds a prominent position in public life – for example a senior member of government or law enforcement – making them more vulnerable to bribery and corruption.

Sanctions searches and PEP screenings are a central component of your AML checks, as they confirm that your client doesn’t present a money laundering risk. 

Get the help you need

The SmartSearch system completes Sanction and PEP screening on every AML check you perform, automatically triggering Enhanced Due Diligence on any matches. It then screens all customers every night and alerts you of any changes.

There’s no official source that lists all sanctions, PEPs and RCAs, so manual screening is challenging. What makes SmartSearch screenings so accurate? We use the Dow Jones WatchList – a combination of over 1,100 databases, updated daily.  

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That's where we come in

SmartSearch offers a one-stop-shop for all your firm’s AML requirements. The user-friendly system enables staff at any level to successfully run AML checks, and we are constantly updating and improving the platform to ensure it remains the leading AML solution on the market.

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What is a Politically Exposed Person (PEP)?

Politically Exposed Persons (PEPs) are individuals who hold prominent political positions or have been given high-profile public roles in the past 12 months. Given the high-ranking posts they occupy, these people possess a greater risk of engagement in money laundering or terrorist financing.

Generally, PEPs are considered to be prone to bribery and financial crimes due to their influential position, wealth, and access to funds and sensitive information. As such, regulated firms and other organisations must take extra steps to ensure that they are not engaging in any suspicious activities.

Under UK regulations,, UK Politically Exposed Persons (PEPs) are considered low-risk unless a firm has identified other factors that pose a higher risk. Therefore, firms must apply enhanced due diligence requirements to UK PEPs and their families, as well as known close associates. However, when determining how best to handle the risk, firms should take into account the nature of the PEP's responsibilities.

Types of Politically Exposed Persons

It can be difficult to determine and recognise a PEP since it varies between countries. However, the UK considers the following individuals as PEPs:

Members of parliament
Senior members of the government and government-owned companies
Senior figures of the armed forces
High-profile members of law enforcement agencies
Board members of central banks
Individuals who serve on supreme courts, constitutional courts or other high judicial boards, and whose verdicts are typically not eligible for additional challenge

Those close to high-profile individuals, like family members, friends, or business associates, may also be considered RCAs (Relative and Close Associates) as they could become used as leverage by criminals.

Identifying PEPs, their associates, and their connections are a vital part of KYC and AML protocols in order to detect or prevent possible money laundering.

How to mitigate risks and monitor PEPs effectively

Once you've determined that your customer is a Politically Exposed Person (PEP), it's crucial to assess their risk level, as well as consider the type of business they may be requesting from you. This will ensure that your due diligence is risk-appropriate, thorough, and ultimately effective.

PEP identification and monitoring is an essential step for avoiding money laundering. It is essential to monitor your business activities to prevent money laundering and other financial crimes. Once the initial due diligence process is complete, these checks should be conducted periodically for both identified PEPs and other customers.

Here are just some processes and procedures your organisation can implement to manage PEP relationships:

Identification upon onboarding: You must assess whether a client is a PEP before beginning the relationship, as mandated by relevant laws. From here, it's important to regularly monitor the relationship once you've chosen to onboard a client with this status.
Identification of existing clients: Your current clients could become a PEP at any point in time. Any client could embark on a political career after due diligence has been carried out. AML-regulated companies have an obligation to conduct regular PEPs monitoring in order to detect any changes in a client's position.
Risk assessments: If a customer is flagged as a PEP, regulated firms should promptly implement adequate due diligence protocols.
Enhanced monitoring: When partnering with a PEP, diligent surveillance must be done in order to confirm that no suspicious or uncommon activities are occurring.

It's essential to check regularly, as a person's PEP status can change quickly. If a customer who was formerly lower in ranking gets promoted to a job that requires them to be on the politically exposed person list, it is your responsibility to monitor this situation.

A software solution, such as SmartSearch, that automates the ongoing monitoring process, sends alerts when any changes occur in a client's PEPs status, and assists with remaining compliant, is the most reliable method to make sure no records slip through.

AML compliance: The importance of an integrated KYC solution

It is essential for any business dealing with legal obligations to have robust KYC procedures in place. The UK regulators are concentrating increasingly on strong protocols in response to the persistent problem of money laundering and terrorist financing in the UK. Using KYC, companies can reduce legal risks and financial crime by building a sustainable legal foundation. This procedure involves monitoring the validity of documents submitted and detecting suspicious transactions.

Frequently employed throughout application procedures, KYC assists in verifying and determining the customer's identity. The aim is to confirm that a possible or current customer is who they declare they are. Accordingly, KYC mainly functions as an identification validation process.

Regulation continues to evolve rapidly, pushing companies to conform to KYC guidelines. Know Your Customer standards are developing in order to prevent financial crimes, preserve privacy and protect consumer rights. 

As an increasing quantity of activities come under the scope of AML regulations, with higher sanctions and heightened customer expectations for data security, businesses must be aware of the criteria they are expected to meet by the countries they do business in.

Nevertheless, adhering to and staying on top of KYC regulations can be difficult.

What are the benefits of digitising your AML/KYC process?

Digitising your AML/KYC process can give many benefits over hand-operated processing. Companies that accept this technology gain from more rapid, precise screening and monitoring. With technology progressing continually, keeping ahead of fraudsters and financial criminals is indispensable. It's time to alter your compliance protocol with industry-leading software that does the difficult work for you.

Faster and more accurate screening and monitoring: 

Manual processes for AML checks can be labour-intensive, time-consuming, and tedious; however digitised processes allow you to quickly pull data from multiple sources in order to detect any suspicious activity. Automating certain tasks ensures a quick response time to address any red flags that may come up, and allows you to monitor risks such as PEPs or sanctioned entities in real time so you can take immediate action when necessary.

Increased customer satisfaction: 

By following the best practices in customer due diligence and KYC compliance processes, you can improve your service quality and efficiency while bypassing the hurdles of manual paperwork. Ultimately, this streamlined approach boosts customer satisfaction levels.

Cost savings: 

The use of digitised compliance software increases efficiency for your staff, as it removes manual processing from their workflow. Electronic processing therefore significantly reduces costs incurred from labour-related expenses.

Improved compliance and higher accuracy:

Electronic AML checks streamline the onboarding process and help ensure customers’ compliance with any existing regulations. It also provides auditable evidence of regulatory due diligence that may be required by regulated firms or government bodies. Moreover, SmartSearch meets the requirements of the Financial Action Task Force (FATF) and EU member state regulators and ensures clients meet their obligations related to sanctions screening or anti-money laundering procedures in businesses worldwide. This highly developed technology elevates precision, minimising false positives and human error.

With TripleCheck, you can perform instant PEP and sanction checks anywhere, anytime

TripleCheck is a powerful KYC software developed by an experienced security engineering team. It offers advanced features such as face-matching technology, document authentication, and optical character recognition.

With TripleCheck, completing a KYC check only takes two seconds. All you need to do is enter some basic information such as name, address and date of birth into the system - it's that simple. And since all data is processed securely via SSL encryption, you can rest assured that all personal details are kept safe from potential threats.

Document verification

The first step with digital KYC is to verify government-issued ID documents for any forgery or other issues as per organisation policy guidelines. To do this, a customer will be asked to upload an image of their ID documents for further examination. Optical Character Recognition (OCR) technology helps automate the process of identity verification. OCR algorithms are used to analyse documents such as passports or bank account statements in order to extract relevant data for further verification purposes. Additionally, AI techniques are employed to scan through digital documents for specific patterns or discrepancies that could indicate fraud.

Facial verification

Your customer will then be sent a link via email to upload an image of themselves to enable further checks. To make sure that customer data is legitimate, liveness detection technology is used to compare the ‘real person’ (the selfie) with a document provided. Recently, Selfie Liveness Video (SLV) has been used as a preferred method of facial verification due to its ability to detect fraudsters more accurately and quickly. 

Fraud screening

TripleCheck aids companies in recognising fraudulent identities and compliance risks by cross-checking data from the customer or taken from a document to reliable international sources such as credit databases, PEPs, sanctions, and negative media watchlists. If any irregularities are spotted or there is a failure to verify customer details, our system will automatically trigger Enhanced Due Diligence for further inspection.

TripleCheck creates a comprehensive report that allows your compliance personnel to assess the provided fraud risk score, PEP status, and any applicable sanctions. Our all-encompassing, innovative AML compliance solution covers all the bases to help your business comply with regulations and battle financial crime and fraud. 

What other advantages does implementing KYC bring to your businesses?

Businesses subject to AML regulations must take measures to prevent them from being in any way involved with money laundering or related offences. Even if your company doesn't have to follow official know-your-customer (KYC) protocols, there are various advantages for both you and your clients from undertaking KYC checks:

If KYC checks are ignored, your brand could be put in jeopardy and cause potential customers and investors to avoid it. 
Effective KYC checks ensure a quicker, smoother and risk-free onboarding process that helps you to provide optimal customer service from the offset.
KYC can help you identify fraudulent or suspicious activity within your customer base. By scanning documents, verifying digital identities and asking additional authentication questions, businesses can reduce the risk of fraud by onboarding new customers who are more likely to be legitimate.
A major benefit of implementing a KYC policy is that it helps build trust between customers and businesses while simultaneously improving brand value. This creates an ecosystem where trusted digital identities are managed securely to deter fraudsters from accessing confidential information.

The importance of enhanced due diligence for PEPs

In the UK, regulated businesses must adhere to AML regulations and carry out enhanced due diligence (EDD) on all domestic and international Politically Exposed Persons (PEPs), as well as their family members and close associates, both current and former. 

A more thorough investigation, known as Enhanced Due Diligence (EDD), is a KYC process conducted when activities appear to pose a greater risk of money laundering and terrorism financing. Simply put, this is an extended version of standard customer due diligence that digs into more data and information about an individual or business. 

The purpose of enhanced due diligence is to provide an in-depth evaluation of the risk posed by high-risk clients to maintain compliance and minimise the risk of money laundering.

When should Enhanced Due Diligence be carried out?

By law, all regulated firms must meet Anti-Money Laundering (AML) regulations and carry out Enhanced Due Diligence (EDD) when necessary. In cases when the risk for customers exceeds the scope of standard customer due diligence, enhanced due diligence is required.

However, there are some situations that specifically trigger this procedure including:

Signs that suggest that there is a higher risk associated with an ongoing business connection. This could be through conversations with an individual or suspicious activity.
If a customer or business partner is determined to be a PEP or is pointed out as closely related to them, it means that the individual has strong connections with those in positions of public power and may be engaged in money laundering and other illicit activities. This would therefore require further investigation.
When there is an obvious money laundering risk, such as a suspicious transaction that cannot be justified or a customer who has raised red flags, careful examination is required.
Fraudulent activity may take place when a customer provides incorrect or stolen identification documents or information when opening an account. If there are any suspicions around this, EDD must be carried out immediately.

These higher-risk scenarios would require EDD measures to be implemented. It should not be assumed that customers in these situations are involved in criminal activities, rather, they just have a greater risk factor that requires additional inspection or ongoing monitoring. 

How to effectively perform enhanced due diligence on PEPs

Regulated firms should implement strong anti-money laundering protocols when dealing with politically exposed persons, according to the Financial Action Task Force (FATF). The FATF guidelines state that any additional screening done on PEPs is not intended to imply criminal behaviour. Rather than steering clear of dealing with politically exposed persons (PEPs), the aim of this screening is to take additional measures to ensure they have not been compromised and are not engaging in financial misconduct. 

Enhanced due diligence efforts typically address risk factors in three key areas:

  • Client data

    This data covers the political affiliations and connections to PEPs of potential clients, as well as any business activities that may raise the risk of money laundering, like those involving large amounts of cash. This data can be located from numerous sources, including government lists, public records and internet and media sources.

  • Location

    Each nation carries its own money laundering risk level, i.e. inadequate anti-money laundering legislation, political corruption vulnerability or terrorism financing designation. The UK has an ever-evolving list of high-risk countries as listed in schedule 3ZA of Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017. It is essential to implement due diligence measures when engaging in any transaction or business dealings with people from a high-risk third country.

  • Transaction activity

    If there is evidence to suggest that PEPs use private high net-worth banks, and if the activities of these banks are unclear, then there is a greater chance for money laundering to take place since it would be difficult to keep a close watch on the financial activities.

Identify the source of wealth

One aspect of conducting due diligence related to a client's wealth is researching their sources of income/assets. This includes verifying that money has been transferred from known locations or sources with proper documentation if needed. It’s also important to research how long an individual has been employed by an organisation before conducting due diligence related to their wealth.

This process should evaluate non-financial and financial assets to verify that they align with the value of their physical assets. Should any discrepancies be seen in their net worth, wealth source, or earnings, then they must be investigated further.

Monitor ongoing transactions

UK and foreign PEPs should be monitored continually in order to detect any potentially suspicious activity throughout the duration of the relationship. By conducting PEP transaction monitoring, trends can be identified to assess the level of risk for further assessment.

Staying informed of sanctions is also critical; SmartSearch's software will alert users in the case of any sanction imposed on an individual.

Investigate adverse media coverage

It’s essential to be aware of any adverse media coverage concerning your PEP customer - this means finding articles related to inappropriate activities carried out by them or those associated with them, such as family or associates. This can often give you important insights into their background and help inform your decision-making process surrounding their customer relationship. Previous reports of financial misconduct - even if found to be untrue - should be carefully monitored in the future. Your business is highly susceptible to financial crimes if there is a history of involvement.

Write up an ongoing strategy plan

After compiling and analysing the data from both the PEP's interview, as well as any public databases in relation to them, create a report that details what is known about them. This will provide other team members with the necessary information to make an informed decision on if they should proceed with taking on the said customer. Be sure to thoroughly document all your findings, including any past reputational risks that can pose a potential threat.

This report should feature a timeline for when to conduct the monitoring activities. 

Sanctions and sanction screening tools explained

Sanctions screening is a key component of the fight against financial crime, as it allows businesses to recognise transactions involving persons on sanction lists and consequently uphold international regulations whilst decreasing their risk of involvement with immoral or unlawful scenarios.

Sanction screening allows organisations to comply with international laws as well as protect against accidental involvement in money laundering events, terrorist financing operations and other financial crimes. This type of check also reduces the potential risk of being on the receiving end of a financial crime when doing business with overseas entities. Additionally, complying with sanctions laws can protect organisations from costly legal action and reputational damages associated with violating these policies.

Some of the following criminal activities can result in an entity or individual being placed on a sanctions list include:

Money laundering
Funding activities that support the planning or execution of terrorism
Trafficking drugs, people or weapons
Financing the production or transportation of illicit or unregistered firearms

What are sanction checks?

Sanctions screening is the process of ensuring that no transactions are performed with individuals or entities that have been banned from engaging in certain activities or dealings.

People and entities who have violated international law or posed a threat to global stability have been listed on sanctions screenings in computer-generated databases maintained by governments and international organisations. 

Sanctions are a common form of punishment used by governments to penalise and force those individuals who appear on sanctions lists to conform to compliance, also known as 'designated people'.

Sanctions are typically imposed in the form of economic, diplomatic, or political penalties. These measures also include:

  • Trade embargoes

    Trade embargoes limit the flow of imports and exports from targeted countries. To impose a trade embargo, specific trade relations between two nations must be broken down entirely. As a result of reduced trade ties with the target country, businesses may not be able to source necessary products or materials and face financial hardship due to inflated prices for products within the embargoed country.

  • Prohibitions on trade

    Prohibitions can also take the form of limitations on certain types of trade from a certain nation. For example, some nations have prohibited importing military supplies from certain countries that are deemed hostile. This restriction applies regardless if the particular arms manufacturer is responsible for prior issues in the region or not; any business tied to that nation is subject to such sanction unless explicitly noted by governmental authorities at home or abroad.

  • Asset freezes

    Asset freezes are an additional method used by governments to place economic sanctions on other nations. This type of sanction mandates the complete freezing of any banking accounts belonging to individuals or entities affiliated with another nation’s operations - whether they reside in that nation or another one - in an effort to further isolate them financially by depriving them access to funds secured within those accounts.

  • Travel Bans

    Travel bans restrict citizens’ activity inside a foreign nation's borders as well as deny entrance into one's own nation to individuals sanctioned.

The necessity of sanctions screening in fighting financial crime

Organisations must check if their clients are listed on a sanctions list before engaging in any type of financial transaction with them. By conducting stringent checks with reliable databases and sources, they can ensure compliance with AML regulations. 

Complying with AML regulations requires all organisations to conduct sanctions screening in order to prevent criminal activity, damage to reputation, and financial loss from participating in illegal trading transactions, money laundering, and terrorist financing.

It is impossible to apply a universal approach when dealing with the ever-evolving laws related to sanctions compliance, as each institution must create its own plan reflecting its particular business activities, geographic location and currencies used.

Navigating sanctions lists can be a daunting compliance task for businesses that handle large volumes of customers and transactions. To help simplify the search process, these businesses may find it useful to incorporate automated screening technologies, like SmartSearch's platform, into their search system. 

At SmartSearch, we collaborate with you to identify the most effective way our software can be incorporated into your existing system. We provide tailored solutions and a variety of choices to help strengthen your AML process.

Beyond onboarding: Why is ongoing monitoring of PEPs and sanctions important?

In high-risk industries, it's not enough to only do a single sanction and PEP screening during the onboarding process. In order to meet the rigorous regulations in place, regular assessments must be completed to keep up with any changes. 

For companies to maintain an effective risk assessment process, they must keep up-to-date with the constantly changing sanctions lists from organisations such as the UN and EU, including any new entries or expungement.
In order to adjust for these changes, companies need to ensure they stay up to date with any changes in their customers' risk profiles. This means assessing their screening technology on a regular basis to make sure it is still collecting the necessary data and generating the right notifications.
Organisations that leverage a sanctions screening provider will benefit from automatic updates to official blacklists, however, some restrictions may be announced through official sources such as the news prior to being reflected in official lists. To ensure they're made aware of all changes, firms can apply extra screening tools such as PEP screening and adverse media screening.
Likewise, certain modifications to laws in certain countries and sanction conditions may demand companies to fundamentally modify their screening protocols in order to adhere to new legal requirements.
cyber security, professionals working

Your international sanctions screening will be fast, accurate, and precise with SmartSearch's software.

SmartSearch's advanced system is able to conduct automatic screening for sanctions, along with a rigorous anti-money laundering verification process. With access to the Dow Jones WatchList which comprises 1,100 databases around the world, we're able to match your potential client or customer's details with accuracy, even if they are registered under nicknames or abbreviations. 

  • Employing automated sanction screening services is an effective and dependable way for companies to comply with Anti-Money Laundering regulations and avoid risks related to sanctions infringements. We can eliminate any false positives that may appear on the records so you won't have to waste time conducting due diligence on invalid individuals.

  • Automated sanction screening services simplify compliance processes and minimise human error by quickly detecting potential issues within customer data. Our solution decreases the costs of manually reviewing customer information due to no longer needing additional personnel as would be the case with traditional methods.

Employing automated sanction screening services is an effective and dependable way for companies to comply with Anti-Money Laundering regulations and avoid risks related to sanctions infringements. We can eliminate any false positives that may appear on the records so you won't have to waste time conducting due diligence on invalid individuals.
Automated sanction screening services simplify compliance processes and minimise human error by quickly detecting potential issues within customer data. Our solution decreases the costs of manually reviewing customer information due to no longer needing additional personnel as would be the case with traditional methods.

Discover the powerful capabilities of our cutting-edge AML technology

As financial crime continues to rise, it's becoming increasingly important to protect your business with the most effective anti-money laundering (AML) solutions on the market. Fortunately, there is now a cutting-edge AML platform that offers powerful capabilities and can help you stay compliant with regulations while optimising your process flow.

Our award winning compliance platform allows our customers to accurately and efficiently identify both UK and global individuals and businesses. It is the only KYC software with full sanction, PEP checking, and continuous monitoring services, meaning that clients can rely on this single tool for all their Anti-Money Laundering requirements.

Frequently Asked Questions

  • What are financial sanctions?

    Financial sanctions are legal restrictions, put in place by the government to limit or prevent entirely the trading of individuals, companies or whole countries. They are usually levied against people or corporations who have committed financial crimes, and fall into one of three categories: the freezing of assets, specific restrictions on financial markets and orders to cease all trading.

  • What are sanctions lists?

    Used by financial authorities and governments all over the world, sanctions lists are databases which detail all the financial sanctions that are currently active in a specific state, country or continent. Some of the most well-known examples in the industry are the United Nations list, the UK Consolidated list and the EU Consolidated list.

  • Which sanctions are included in the UK sanctions list?

    The UK Consolidated list, which is the most widely used official list of financial sanctions in the UK, details three types of sanctions. These are the following: targeted asset freezes, financial restrictions and directions to cease all business.

  • Which countries are subject to sanctions?

    Every country is legally obliged to adhere to any financial sanctions levied against it, if it’s enforced by the relevant authorities (for example, the Office of Financial Sanctions Implementation in the UK).

  • What are the risks when you fail to screen for sanctions?

    If you fail to include a sanctions search when carrying out your AML checks, you could end up unwittingly entering into business with a client or customer who is currently sanctioned. In the UK, having dealings with any sanctioned business or individual is illegal if those dealings break the terms of the arrangement, except in very specific circumstances when a license is required. If you’re found out, the consequences can include substantial fines or even a prison sentence, as it’s considered an AML compliance failure.

  • Which organisations need PEP verification?

    Depending on the jurisdiction, increasingly more industries are required to practise anti-money laundering compliance these days, whereas traditionally only regulated firms had to comply. This could include:

    • Firms looking to purchase and sell property

    • Businesses that sell high-value items such as antiques and expensive collectables

    • Firms that provide financial services, such as hedge funds or accountants

    • Online gaming and gambling companies

    It is advised to contact your local regulatory body to determine if your company needs to abide by AML regulations.

  • Can I still work with someone on a sanctions list?

    Regardless of the circumstances, when collaborating with others, you must not partner with anyone who is sanctioned by the government. This includes their close family members and associates.

  • When should a PEP check be carried out?

    A PEP (Politically Exposed Person) check should be carried out when onboarding new customers to ensure that they are not linked to any form of financial crime. For example, if a customer is a government official or a family member of a government official, it is important to conduct a PEP check as such individuals may be involved in bribery or corruption. Additionally, a PEP check should be performed whenever changes are made that could trigger the need for additional verification. This could include changes in address, profession, or banking details which may indicate potential money laundering activity.

  • Can I still work with a Politically Exposed Person?

    Organisations can legally provide services/products or choose to work with PEPs; it is their responsibility, however, to manage the risk associated with doing so.

    Regulated industries, especially those in the finance sector, are required to conduct PEPs and sanctions screening as part of their Customer Due Diligence (CDD) during onboarding. After conducting their checks, they may require further verification before making a decision on whether or not to accept the customer. CDD steps are just a part of the Know Your Customer process.

    Failing to abide by the nation's AML protocols can result in financial penalties and even jail time.

  • How long is someone considered a PEP?

    The time frame a person is deemed to be a PEP may vary depending on their particular function, with designation potentially lasting up to a year after their official departure. To guarantee adherence and surveillance, a thorough assessment must be conducted into the individual and their prior connections before PEP status is cleared from them.

  • What are my responsibilities when choosing to work with a PEP?

    When onboarding a Politically Exposed Person according to Regulation 35 of the Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017 (MLR 2017), you must:

    • Secure approval from upper management for the business association.

    • Ensure the origin of assets and funding is adequately investigated.

    • Keep a close eye on the business relationship over time

    Regulated businesses must ensure they meet KYC and AML regulations by performing PEPs and sanctions checks as part of their due diligence process.