Keeping the tainted funds of corrupt politicians and their networks out of the legitimate financial system is a vital outcome of effective Know Your Customer (KYC) procedures. Organizations need to perform a detailed politically exposed person (PEP) and sanction check when onboarding new customers, as well as during the ongoing review of clients, to ensure that the organization’s reputation, revenue and capital are protected.
Financial institutions (FIs) that neglect to identify PEPs and breach sanctions put themselves at risk of fines, which can be quite significant. Between 2008 and 2018, regulators around the globe levied almost $27 billion in fines related to watchlist screening. Notable offenders include BNP Paribas (fined $9 billion in 2014), Societe Generale (settled for $1.3 billion in 2018) and Standard Chartered (fined $1.1 billion in 2019).
Types of screening
A thorough screening program includes two types of checks:
- Sanctions screening to ensure that no individuals on global law enforcement and sanctions lists are allowed to make financial transactions
- PEP screening to identify and conduct CDD on any PEPs or other high-risk customers
These watch lists are continually updated with new names. So both the sanctions and PEP screening should be done in real time to adhere to KYC requirements and to create a seamless customer onboarding process.
What are the sanctions lists?
Sanctions lists are established to help reduce financial crime by flagging people, businesses and countries that have committed illegal acts (or are suspected of committing them). By screening customers against sanctions lists, organizations can lower their risk of doing business with sanctioned entities.
These sanctions lists are a compilation of various regulatory and enhanced due diligence lists from major sanctioning bodies around the globe, such as the Office of Foreign Assets Control (OFAC), UN sanctions, EU sanctions, Her Majesty’s Treasury and thousands of other regulatory and law enforcement lists like Interpol.
What is a PEP (politically exposed person)?
FATF Recommendation 12 defines a PEP is an individual who is or has been entrusted with prominent public functions either domestically or abroad, such as, for example, a head of state or senior politician. The PEP list also includes close business associates and family members. As these individuals have influence, or potential influence, over government contracts and oversight functions, their ability to enable corrupt activities requires special attention.
PEP requirements in the U.S. and UK
Taking measures to identify the accounts of PEPs and the associated risk is a requirement in both the U.S. and UK. Accepting such accounts should be a decision of senior management.
In the United States, the broad definition of PEP is someone who holds a senior position of public trust or people close to them, such as family members, professional associates, or people who conduct transactions on their behalf.
In the UK, however, the term PEP only applies to people who hold high public office. However, family members or close associates of PEPs are considered higher risk and thus Enhanced Due Diligence procedures are called for.
Why it is important to screen against PEPs and sanctions lists
Transacting with customers who appear on PEPs and sanctions lists puts organizations at greater risk:
- Non-compliance with watch list screening may expose an FI to steep regulatory fines
- Failure to identify sanctions evasion, bad actors or a PEP involved in organized crime may lead to potential reputational damage
Standard compliance procedures don't generally involve “high-risk individuals and entities.” Running watchlist checks that examine occurrences on PEP or other sanction lists helps protect your organization.
Integrate with high quality and wide range of trusted data sources
To ensure you are identifying sanctions from all relevant bodies, the data you screen your customers against must be comprehensive and up to date and, ideally, consolidated all in one place with other watch list databases.
Perform a risk-based approach
The FATF recommends taking a risk-based approach to PEPs. An internal risk assessment, for example, will help define what does and doesn’t constitute politically exposed according to an FI’s policies and risk appetite.
Conduct ongoing monitoring
Automate ongoing monitoring of individuals and entities against up-to-date PEPs and sanctions lists to monitor your customers daily and alert you immediately of any changes to a customer’s circumstance or status, helping to ensure ongoing compliance with AML regulations.
Rely on best-in-class technology platforms
To improve the effectiveness of sanctions and PEP screening processes, and to automate much of the associated workload, financial institutions can also implement AML/KYC solutions designed to help mitigate AML risks. A single API-led solution can pull information from various sources to help screen customers against sanctions and PEP databases. With cutting edge technologies such as artificial intelligence and machine learning, FIs can also reduce false positives and thereby increase efficiencies in their screening process.
Automatic watch list screening and ongoing monitoring, coupled with a global identity verification platform, is a smart and economical way to make it more difficult for corrupt people to launder their illicit fund and thus safeguard an FI’s reputation and integrity.