PEP check: how to tell if someone is a PEP in 5 steps

The usual picture of a PEP check is a lookup in an official list. No such list of names exists, and FATF's guidance on politically exposed persons (June 2013) warns that a name missing from a list or a database does not prove the person is not a PEP (paragraphs 62 and 64). The check is a short investigation across sources, five steps for one person. The program around it is set out in the PEP screening guide from complead, formerly Sanction Scanner.

What makes someone a politically exposed person?

A politically exposed person is someone who is or has been entrusted with a prominent public function. The FATF Recommendations glossary (updated June 2026) names three groups: foreign PEPs, domestic PEPs, and the directors, deputy directors and board members of international organizations. Its examples run from heads of state and senior politicians to senior judicial and military officials and the executives of state owned corporations. Middle ranking and junior officials are left out. Which posts count differs from one government to the next (guidance, paragraph 66).

Recommendation 12 applies the same measures to family members and close associates. The EU directive (Article 3, points 10 and 11) names as family the spouse or equivalent partner, children and their spouses, and parents. Close associates jointly own a company or arrangement with a PEP, have any other close business relations with one, or alone own an entity set up for a PEP's benefit. The FCA's FG25/3 guidance (July 2025) adds siblings and says relatives and associates are not PEPs solely because of the connection.

Picture a payments firm (illustrative) onboarding a consultancy whose majority owner is married to a serving deputy minister. The owner is a family member. PEP rules therefore reach the company through its beneficial owner (UK regulation 35(1)).

Why is there no official PEP list to check against?

Picture a cabinet reshuffle on a Friday (illustrative). Six new deputy ministers take office, and one of them opened an account with you on Thursday. A list of names compiled last month cannot show that, and FATF says the same of commercial databases: with elections, cabinet changes and turnover among officials almost daily, such lists cannot be relied on as up to date (paragraph 62).

FATF does not require governments to publish PEP lists either. It advises against lists of names, which go out of date quickly and leave out family members and close associates, and calls a list of functions an important source (paragraphs 64 to 66). The EU took that route. Article 20a of the directive has each member state list the exact functions that qualify, and the Commission assembles the national lists into a single public list of prominent public functions.

Commercial PEP databases draw on publicly available information (paragraph 62), so they are built by reading official sources country by country.

What details should you collect before the check?

A bare name returns namesakes. Collect five things first, for the customer and, when the customer is a company, for each beneficial owner and director.

• The full legal name and every spelling of it. FATF lists inconsistent transliterations and spellings among the limits of PEP databases (paragraph 62), so one person can sit under several records.
• The date of birth, which sets most namesakes aside.
• Nationality and country of residence, which point to the countries whose office holders to check. UK rules start a PEP entrusted by the UK at a lower level of risk than a foreign one (regulation 35(3A)).
• Occupation and any public role, now or in the past. FATF counts a declared occupation that is plainly a public function as one way to identify a PEP (paragraph 76).
• The customer's own declaration. A PEP declaration form asks whether the customer or any beneficial owner, director or authorized signatory holds a prominent public function now or did in the last 12 months, or is a relative or close associate of someone who does, and asks for the position, country and dates in office.

FATF warns firms not to rely on it alone, because many customers do not know what the PEP definition covers (paragraph 77).

How do you check if someone is a PEP?

Run the steps in this order for each person, and note what each one returned.

1. Screen the name against PEP data. Type the full name into the free PEP check. It searches global PEP records in Class 1, Class 2 and the family and close associates group, with no account, and lists the hits on screen. A PDF report by email gives each match's country, date of birth and aliases. FATF notes that free search tools on AML websites give more targeted results than a general search engine (paragraph 60). A commercial database for the whole customer book is optional under FG25/3, and FATF calls one insufficient on its own (paragraph 61).
2. Confirm each hit on official sources. FG25/3 names the websites of parliaments and governments, the Companies House register of persons with significant control and the Electoral Commission's registers. A hit reading "member of parliament, 2019 to 2024" (illustrative) is checked against the parliament's own list of members.
3. Search the news. FATF lists internet and media searches as a source and warns that what they return is not always complete or reliable (paragraph 60). A free adverse media check looks for reporting that links the same name to fraud, money laundering, bribery or sanctions evasion.
4. Read asset disclosures where a country publishes them. FATF notes that they can carry dates of birth and identification numbers (paragraph 74).
5. Record the decision. Write down what was searched, what each source showed and who decided, since FG25/3 wants the risk assessment and the choice of enhanced measures clearly documented.

What does each hit in a PEP check result tell you?

Read every hit on four points: the identifiers, the position and its class, the dates in office, and, for a relative or associate, the relationship. In complead's free PEP check, Class 1 holds national figures such as ministers and central bank officials, and Class 2 holds senior civil servants, regional and local officials and the heads of state owned enterprises. Picture an analyst (illustrative) checking Ana Doru, an invented name: born 14 March 1984, a Moldovan national living in Romania. The check returns three hits.

The first, a Class 2 regional council member born in 1957, fails on the date of birth. The second is in the family group: the daughter of a serving minister, born in 1984, Moldova. Name, year and country agree. It stays open until the ministry's website and the customer's declaration confirm or clear it. The third, a Class 1 supreme court judge in another country, has no date of birth and matches on the name alone, so the analyst records why it was set aside.

Check the rank as well as the name. FG25/3 says that in the UK, public servants below Permanent or Deputy Permanent Secretary need not normally be treated as holding a prominent public function.

What if the person has left office?

FATF wants a former PEP handled by risk rather than a fixed time limit, weighing the influence the person may still hold and the seniority of the old post (paragraphs 44 and 45). The EU directive (Article 22) and UK regulation 35(9) set a floor of at least 12 months, and longer where the risk remains. Under regulation 35(11), the measures for a former PEP's family members and close associates end when the PEP leaves office.

What does a confirmed PEP match require?

Table 1. What a confirmed PEP match requires, by jurisdiction (as of November 2026)

Outside the United States, every row asks for the same three measures: senior management approval, adequate measures on the source of wealth and source of funds, and enhanced ongoing monitoring. They make up the PEP branch of enhanced due diligence.

A confirmed match is a reason for more checks, and the FCA expects firms not to decline or close a relationship merely because someone meets the PEP definition; only risks a firm cannot mitigate justify that. In the US, the agencies' joint statement of 21 August 2020 says the CDD rule does not require banks to screen for PEPs, though a bank may choose to check at account opening. The AMLR row takes over from the directive on 10 July 2027.

How does a PEP check at onboarding go out of date?

Ateshgah Life, Azerbaijan's first life insurer, used to run its sanctions and PEP checks by hand across several databases (case study, July 2026). A check made at sign up was out of date as soon as a customer was later added to a list. FATF describes the same gap: existing clients sometimes become PEPs after the relationship starts, so firms should watch their accounts for a change in PEP status (paragraph 58). Elections are the obvious trigger. FG25/3 expects firms to react to UK election results, which are public, when they change a customer's PEP status.

Ongoing monitoring closes that gap. Client screening and ongoing monitoring on complead keeps checking names after onboarding, using 3,500+ sanctions, PEP and watchlists from 220+ jurisdictions, refreshed every 15 minutes. An API trigger starts or stops monitoring for each name. Each search is logged with who ran it, what was searched, when and the result, no match included, which gives step 5 its record.

One decision sits with your team before the next onboarding: the websites and registers you accept as official, country by country. Step 2 rests on that list. Without it, two analysts can confirm the same hit against different pages and file different answers.