A possible Politically Exposed Person (PEP) match does not automatically mean that your client is a PEP. It means the information provided matches, or closely resembles, an individual recorded on the PEP register and requires your review.
You should download the report and review the information returned. The report contains the details of the potential match, allowing you to compare it with the identity information you hold for your client.
You should carefully compare the details returned in the report with your client's information, including their name, date of birth, nationality, and occupation, to determine whether the match relates to your client.
You can also ask the client directly whether they are a Politically Exposed Person. We recommend obtaining this confirmation in writing so that you have an written trail of their response.
If, after reviewing the report and comparing the available information, you are satisfied that your client is not a Politically Exposed Person (PEP), you can select Manually Verified – No Match from the Action Required drop-down menu.
If you confirm that the client is a Politically Exposed Person (PEP), select Manually Verified – Match from the Action Required drop-down menu.
Where a positive PEP match is confirmed, the client's risk level will automatically be increased to High Risk.
You should notify your Money Laundering Officer (MLO) of the result. If an MLO has been assigned within Movebutler, the system will also automatically send them an email notification.
Depending on the checks that have already been completed, you may not need to carry out any additional identity verification. For example, if the client has successfully completed an Online Biometric ID Verification, this will usually satisfy the identity verification requirements for a high-risk client.
You should review the client's overall Due Diligence Status. If the status is Incomplete, complete any outstanding verification steps or upload the required supporting documents to the client's record before proceeding with the transaction.