Politically Exposed Person (PEP) checks now run automatically through the AMLHUB. Here is a guide to how it works.
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1. When is a PEP check automatically run?
A PEP check is automatically run when you add or change an individual's first name, last name, country of residence, and date of birth.
2. How does the automated process work?
When AMLHUB detects a change to these fields, a check is run to see if the details match any entries on the Dow Jones global PEP register.
If no matches are found, a no-match PEP check is recorded against the individual, and no further action is required.
If any matches are found, the list of matches and their full details are loaded and recorded against the individual as an unconfirmed "Enhanced PEP" check.
The Enhanced check does not imply that the individual is actually a PEP; the potential matches must be manually reviewed, and the PEP check "confirmed" to indicate which of the potential matches (if any) are the individual in question.
If none of the potential entries are a match, and the PEP is resolved as "No Match", and no further action is required.
If a match is found, the user must indicate which entry matches. The AMLHUB system then automatically sets the "High Risk" flag on the individual records.
Refer to your AML Policy document to ensure compliance with the organisational PEP / Enhanced DD requirements.
3. How to access/review the Enhanced PEP check results
In the AMLHUB platform, navigate to a deal and open the details for an individual. Switch to the eChecks tab in the details panel. Note that PEPs are not visible in the mobile interface.
Click on the Enhanced PEP check.
Review the list and see if there are any matches.
Each list entry can be expanded to display additional detail about the potential match, including (if available) country of residence, position, relationship to a PEP (for spouses for example).
Note that the "100% match" indicates a data match only - individual details must be reviewed to confirm a match.
Click YES / NO to indicate if any potential matches are your individual. In this example we press NO.
The status of the enhanced PEP will update accordingly.
5. What to do if your client is flagged as a PEP
If your client is a match to the PEP watchlist, there are a few extra steps you will need to take in their AMLHUB record to resolve it.
Under eChecks, click on the status of the Enhanced PEP check.
Review the potential matches.
Click the down arrow to view more information.
If you have found a match, select 'YES'.
Select the entry from the potential matches
They will be marked as a confirmed match.
Confirming a match causes AMLHUB to automatically mark the individual as a PEP, and set the High Risk flag:
Note that if an individual is indicated as a PEP in error, your AMLCO will need to be engaged to "undo" that determination.
5. What to do if a PEP client is not found in PEP check
If the client informs the agent that they are a PEP ("my spouse is the Minister of...") but they are not found in a PEP check, the individuals must still be recorded as a PEP:
Open the individual's record in the AMLHUB platform and set the Offshore Exposure Risk flag:
Confirm the PEP determination:
3. Confirmation of their status will be displayed under the PEP tab.
6. How can I run a manual PEP check?
When re-using an individual's record in a new deal it's possible that a PEP check had not ever been run previously, and the details (name, DOB, country of residence) have not changed. In this instance, a new PEP check can be manually triggered by visiting the eChecks tab:
and then selecting the Enhanced PEP check:
7. What happens with PEPs if I reuse the CDD record of an individual?
If an individual is reused in the AMLHUB and the last PEP is less than one year old, it will stay as is. Otherwise, another PEP check will be run.
8. What does the 'eye' icon mean?
When a PEP check is run, this updates the status of the eye icon for your individual.
 | A green eye icon means the PEP check has passed or has been resolved. |
 | An orange eye icon means the PEP check is unconfirmed and needs to be resolved. |
 | A red eye icon means the PEP check found a match and did not pass. |