PEP screening identifies customers who hold prominent public functions, plus their families and close associates. What the obligation actually is, why matching is hard, and how to handle a hit.
PEP screening checks whether a customer, a beneficial owner or someone connected to them holds — or recently held — a prominent public function. Being a politically exposed person is not wrongdoing and not a reason to refuse business; it is a risk factor that triggers extra scrutiny. Two things make this harder than it sounds: the definition extends well beyond the individual, and status changes over time, which means a clean check at onboarding tells you nothing two years later.
Screening tools return possible matches, not answers. Transliteration, name order, common surnames and dates of birth recorded differently across sources produce false positives in volume, and discounting them is judgement work that has to be recorded. The opposite error is quieter and worse: a match missed because the customer was screened under a slightly different spelling, or because only the account holder was screened and not the beneficial owner. Both outcomes are findings — one wastes time, the other is the one regulators penalise.
Screening is not a one-off event. Status changes when somebody is appointed, so the customer base has to be re-screened periodically and on trigger events, and the re-screening date has to be recorded alongside the original result.
Ettex Records keeps the evidence trail: one row per customer with screening date, tool and result, the reasoning for discounted matches, senior approval where required, and the next review date. Filtering by overdue reviews produces the work list, and the same file sits next to the client due diligence record rather than duplicating it.
No. It requires enhanced due diligence, senior approval and closer monitoring, not refusal. Blanket de-risking of whole categories attracts its own criticism from regulators.
Most regimes apply a risk-based approach rather than a fixed cut-off, with twelve months often cited as a minimum consideration period. The assessment should reflect the seniority and the influence retained.
Periodically by risk — higher-risk relationships more frequently — and always on trigger events such as a change of ownership, address or a new signatory.
Terminating an employee needs grounds, a fair procedure, documentation and a conversation handled properly. The sequence that protects everyone, and the mistakes that create claims.
Software team augmentation adds engineers to your team rather than outsourcing a project. When it fits, how to contract it, and the handover that decides whether you keep anything afterwards.
Software asset management software discovers what is deployed, compares it to what you are entitled to, and exposes the gap before a vendor audit does. What it must do, and where the money is.