PEP Screening Process: How UK Firms Should Review Matches
In brief: PEP screening is the process of checking whether a client or relevant person is politically exposed, then deciding whether the match is true and what enhanced measures are needed.
Key points
- A PEP match needs review, not automatic rejection.
- Relatives and close associates may also affect risk.
- The decision record should explain whether the match was cleared, escalated, or handled through enhanced due diligence.
What is PEP screening?
PEP screening checks whether a client, beneficial owner, director, controller, or relevant third party is a politically exposed person. If a possible match appears, the firm should review it, decide whether it is a true match, and record the risk decision.
The UK Money Laundering Regulations include enhanced due diligence expectations for PEPs. See the Money Laundering Regulations 2017.
A practical PEP screening workflow
- Screen the client and relevant connected people.
- Review possible matches against date of birth, country, role, and other identifiers.
- Check whether relatives or close associates create risk.
- Decide whether enhanced due diligence is needed.
- Record approval, evidence, and review frequency.
- Re-screen when risk changes or periodic review is due.
What to record
- Who was screened.
- Date and tool/source used.
- Possible matches returned.
- Why a match was cleared or confirmed.
- EDD measures applied.
- Approval and next review date.
Common mistake
The common mistake is either clearing a match without notes or treating every match as a refusal. A PEP relationship can be managed, but only if the firm understands and records the risk.
This guide is general information and is not legal advice.