PEP and Sanction screening uses an external data provider. They maintain a correlation database of PEP Tier 1, 2, 3 & PEP by association OECD categorises lists which are updated daily from various sources, such as official government websites or national assemblies of foreign offices, CIA World leaders lists, open source verified repositories and selected media websites.
For Sanction screening, the database is collated and updated daily from the following sources: UK HM Treasury, US Department of the Treasury - Office of Foreign Assets Control (OFAC), US Department of State - Bureau of International Security & Non-Proliferation Sanctions, UN Security Council Committees, EU Sanction records, US Defence Trade Controls and other international government and local authority resources.
Sanctions Sources
Please see below a list of sanctions sources that the individuals is checked
Sanctions Source List
Australia DFAT Sanctions List
Austria National Bank - Sanctions
Bangladesh Central Bank - Domestic Sanction List
Belgium - Federal Public Service National Financial Sanctions List
Canada - Freezing Assets of Corrupt Foreign Officials (Tunisia and Egypt) Regulations
Canada - Freezing Assets of Corrupt Foreign Officials (Ukraine) Regulations
Canada Criminal Code - Terrorist Organizations
Canada OSFI Entities List
Canada OSFI Individuals List
Canada OSFI UN Sanctions Act Resolution on Iran
Canada Special Economic Measures Act - Consolidated Sanctions List:
Burma
Iran
Nicaragua
Russia
South Sudan
Syria
Ukraine
Venezuela
Zimbabwe
Dutch Foreign Ministry Individuals & Organizations with Frozen Funds
EU Consolidated List of Sanctioned Persons, Groups, & Entities
EU COUNCIL DECISION 2014/512/CFSP
France Directorate General of the Treasury - Terrorism
India - National Investigation Agency - Banned Terrorist Organizations
Interpol UNSC Special Notices - Entities
Interpol UNSC Special Notices - Individuals
Japan Finance Ministry Asset Freeze List
Japan Ministry of Economy, Trade, and Industry (METI) - WMD End User List
Latvia Financial Intelligence Service - Sanctions
Libya National Transitional Council Law 36
Malaysia Ministry of Home Affairs - Sanctions List
Netherlands - National Sanctions List for Terrorism
Official Journal of the European Union - EU International, Economic, Military Sanctions
Pakistan National Counter Terrorism Authority - Proscribed Organizations
Pakistan National Counter Terrorism Authority - Proscribed Persons
Qatari Linked Terrorist List
Singapore Terrorism (Suppression of Financing) Act List
South Korea Financial Intelligence Unit (KOFIU) - WMD End-User Controls List
Sri Lanka Government Gazette - List of Designated Persons, Groups and Entities
Switzerland State Secretariat for Economic Affairs (SECO) Sanctions List
UK HM Treasury Financial Sanctions Target List
UK HM Treasury Financial Sanctions - Ukraine Restrictive Measures
UK Home Office/Ofc for Security & CT Proscribed Terror Groups
Ukraine State Committee for Financial Monitoring - Terrorism List
Ukraine State Committee for Financial Monitoring - UN Sanctions Program
United Nations Security Council (UNSC) Consolidated Sanctions List:
Resolution 751 (1992) I 1907 (2009) Somalia
Resolution 1267/1989 Al-Qaida
Resolution 1518 (2003) Iraq
Resolution 1533 (2004) Democratic Republic of the Congo
Resolution 1591 (2005) Sudan
Resolution 1718 (2006) Democratic People's Republic of Korea
Resolution 1970 (2011) Libya
Resolution 1988 (2011) Taliban
Resolution 2048 (2012) Guinea-Bissau
Resolution 2127 (2013) Central African Republic
Resolution 2140 (2014) Yemen
Resolution 2206 (2015) South Sudan
Resolution 2374 (2017) Mali
US Department of State - Bureau of Economic & Business Affairs - Cuba Restricted List
US Department of State - CAATSA Section 231(d) List
US Department of State Consolidated Non-proliferation Sanctions
Chemical and Biological Weapons Control and Warfare Elimination Act (CBW Act)
Executive Order 12938
US Department of State Foreign Terrorist Organisations
US Department of State Terrorist Exclusion List
US Treasury Department FinCEN Advisory Notice on Iran, North Korea
US Treasury Department FinCEN Section 311 Measures
US Treasury Department FinCEN OFAC Consolidated Non-SDN Sanctions List
US Treasury Department FinCEN OFAC Specially Designated nationals List
US Treasury Department FinCEN Designated Charities and Fronts for FTOs
PEP Sources and Types
The individual is checked against various global sources to assess whether they are potentially a politically exposed person. Each PEP type helps categorise the type of PEP (e.g. HOS - Head of State).
PEP Sources & Types
PEP Sources
CIA World Leaders
CIA World Factbook
Rulers articles and other databases continually monitored to additional information
Gov’t/Official websites covering all levels of PEPs
Other open sources. For example, those independent from the state control
PEP Types
AMB - Ambassadors and top diplomatic officials
ASC - Family, close associates and advisors
CAB - Cabinet officials
DIP - Diplomats
FAM - Family members
GCO - Top executives/functionaries in state-controlled businesses
PEPs are categorised into tiers of risk. With Tier 1 being the highest potential risk, including heads of state and high ranking government positions.
PEP Tiers
Tier 1 - High Risk
Heads of state and government (including Royal families).
Members of government (ministers, deputies, state, and under-state secretaries) at national and sub-national levels in case of federal states (e.g., Florida in the US, Bavaria in Germany, Johor in Malaysia, Lagos in Nigeria, Goa in India etc) and provinces in China (e.g., Henan); President and College of Commissioner of the European Commission.
Members of Parliament or similar legislative bodies (at national and sub-national level in case of federal states – same as above); Members of the European Parliament.
Heads and top commanders of military and law enforcement and their deputies.
Heads and members of supreme courts, of constitutional courts or of other high-level judicial bodies whose decisions are not subject to further appeal, except in exceptional cases, similar for EU Court of Justice.
Heads and members of courts of auditors (including EU Court of Auditors) and of the boards of central banks (including the European Central Bank).
Top ranking officials of mainstream political parties (e.g., party leaders and members of governing bodies) and only the heads/deputy heads of minor political parties (without representation in parliament).
Tier 2 - Medium Risk
Members of legislative (e.g., aldermen, councillors) and executive (e.g., prefects) bodies at regional, provincial, cantonal, or equivalent levels (below the level of states in case of federal jurisdiction).
Judges, justices, magistrates, prosecutors, attorneys in courts with jurisdiction at regional, provincial or equivalent level.
Ambassadors, general consuls, high commissioners, permanent representatives, head of missions and their deputies, charge d’affairs.
Chairmen, secretary generals, directors, deputy directors and members of the board or equivalent function of international/regional organisations (e.g., UN, EU, World Bank, EBRD, OAS, Arab League, ASEAN, CARICOM etc).
Presidents/Chairperson and board members of State-Owned Enterprises (SOEs), businesses and organisations.
Senior officials of the military, judiciary, law enforcement agencies, central banks, and other state agencies, authorities and state bodies (e.g., high ranking civil servants, director generals, directors, heads of units, secretaries (permanent, principal, joint secretaries etc).
Heads and senior members of mainstream religious groups (e.g., archbishop, patriarch, cardinal, bishop, imam, rabbi).
Mayors of capital cities (e.g., London, New Delhi, Paris, New York, Rio de Janeiro) and Head of Cities which are directly appointed and answerable to the Chinese central government.
PEP Tier 3 - Low Risk
Advisers, heads of cabinet and similar roles of senior officials of the military, judiciary, law enforcement, central banks.
And other state agencies, authorities, and state bodies (designation/level to be determined depending on country ML/TF and corruption risks profile and administration structure).
Heads and board members / senior officials of Trade Unions. In case of Chambers of Commerce and Charities a risk- based approach is followed.
Presidents, secretary generals, directors, deputy directors and members of the board or equivalent function of international NGOs (e.g., Oxfam, Amnesty, Transparency International etc).
Middle ranking diplomats (minister-counsellors, councillors, 1st Secretaries and 2nd Secretaries).
Alternate/deputy members of parliament/senate (not currently occupying seat).
Mayors and members of local councils at municipal, town, village, or equivalent levels (i.e., below regional, provincial, cantonal, and other levels not captured elsewhere).
Senior civil servants at regional/provincial or equivalent levels; senior officials of administrative bodies at local levels (directors/secretaries of city governments).
PEPs by Association
Family members and personal and business associates of PEPs, typically individuals who are not PEPs in their own capacity but serve on a board of directors alongside PEPs. Based on FATF, Close Associates are considered to be: (known) (sexual) partners outside the family unit (e.g., girlfriends, boyfriends, mistresses); prominent members of the same political party, civil organisation, labour, or employee union as the PEP; business partners or associates, especially those that share (beneficial) ownership of legal entities with the PEP, or who are otherwise connected (e.g., through joint membership of a company board). In the case of personal relationships, the social, economic, and cultural context may also play a role in determining how close those relationships generally are (FATF Guidelines, 2013).
Should the individual have a potential match within the PEP & Sanctions sources they will be flagged up for review.
