Module 2 · Chapter 5

PEPs, Sanctions Screening and Enhanced Due Diligence

When an owner holds high public office, a firm may still act, but it checks harder and the managing partner decides. This chapter also shows how to screen for sanctions.

≈ 7 min read 8-question test

In this chapter

  • Who counts as a politically exposed person, and who counts as family
  • Why such a person is a risk to manage, not a bar, and who approves
  • How sanctions screening works, and what a match means

5.1PEPs and sanctions in one paragraph

You screen everyone behind the client before the firm goes further. One check looks for people in high public office, called politically exposed persons (PEPs). If a PEP owns the client, the firm may still act. It needs closer checks, called enhanced due diligence (EDD), and the managing partner’s written approval. The other check is against the sanctions list, and a true match there stops all work at once.

Key point

A PEP is a reason to check harder, not to refuse. A true sanctions match is a reason to stop.

Also in this chapter

  1. Who counts as a PEP, and who counts as family
  2. Why a PEP is a risk, not a bar
  3. Screening against the sanctions list
  4. The managing partner’s approval
  5. Your job

Preview

The rest of this chapter opens with a free account. Every edition is free to read until 31 January. Open a free account by the end of that day and keep every edition published by then, for good. Open it from the edition home →