Politically Exposed Persons Screening: What the File Records

Politically exposed persons screening is a check against published lists of individuals whose public function carries enhanced money-laundering risk. The check produces a documented result for the file. It does not produce a verdict on the individual or the transaction under review.

The screening basis is recorded first. The list provider, the list version, and the date of the screening are noted, so that a later reviewer can confirm what was checked against which dataset on which day. Screening against an outdated list is recorded as such, not silently refreshed.

Match outcomes fall into three categories. A clear match, a possible match requiring adjudication, and a clean result are recorded with the operator who performed the check and the date. Adjudication of possible matches is performed by a second operator and recorded as a separate entry.

Adjudication evidence is preserved. Where a possible match is cleared because of a distinct date of birth, a different middle name, or a different jurisdiction, the basis for the clearance is recorded so the decision is reviewable, not asserted as a single-line outcome in the log.

Where a confirmed PEP relationship exists, the engagement does not opine on whether the relationship is acceptable to the counterparty. The file records the relationship, the nature of the public function, and the date the relationship began and, where applicable, the date it ended.

Family members and close associates fall within the standard PEP definition. The screening therefore checks beyond the principal individual and the file records the relationship type when a connected party is identified, with the source supporting the assertion of the relationship.

Re-screening intervals are documented. A PEP file is not a one-off check. The engagement records the re-screening cadence and the operator responsible, so a change in the principal's public function during the engagement does not go unrecorded until the next periodic review.

Our scope is to structure screening results the client commissions or provides. We do not maintain a proprietary PEP list, do not adjudicate counterparty risk appetite, and do not represent the client in onboarding decisions made by the counterparty. The deliverable is a screening register.