Identifying a PEP Relationship

PEP screening forms part of Keystone's standard client onboarding process.

Where a PEP match is identified, the responsible lawyer must not simply rely on the screening result. They must consider:

• the nature of the public function held;
• whether the function is current or former;
• the jurisdiction concerned;
• the length of time since the position was held;
• whether the individual is a client, beneficial owner, controller, family member or known close associate; and
• whether any wider circumstances increase or reduce the overall financial crime risk.

False positives are common and should be investigated before conclusions are reached.