PEP and sanctions are different checks.
A politically exposed person (PEP) holds, or has held, a prominent public function. Identifying PEP status helps the firm apply the relevant risk assessment and due diligence measures. It does not by itself establish wrongdoing.
Sanctions concern restrictions applying to designated people and entities, and can also involve ownership or control. Treat a sanctions result separately from a PEP result.
HMRC: politically exposed persons (PEPs)OFSI: UK financial sanctions guidanceA similar name needs context.
A screening result can relate to somebody else with a similar name. Compare the available identifiers, such as date of birth, nationality and aliases, before deciding whether the result concerns your client.
AMLCode is designed to bring screening results and identity evidence together for comparison. Your firm reviews any unresolved matches.
OFSI: UK financial sanctions guidanceKnow what “no match” means.
No match describes the result of a particular search against its sources at a point in time. It does not establish that the client presents no risk, or replace the other checks in your firm’s process.
Screening checks the person at the time of the search. Continuous monitoring is not included.
Can a no-match result approve the client automatically?
No. Your firm still needs to assess the client, the relationship and any unresolved information before making a decision.