CONCEPT
Politically Exposed Person (PEP) screening?
What's on this page?The full concept entry as stored in Postgres. Definition, regulatory origin, risk consequence, and any per-jurisdiction overrides and role guidance authored for it. Sources at the bottom are the only citations the AI Generator is allowed to use when producing content about this field.
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What's on this page?The full concept entry as stored in Postgres. Definition, regulatory origin, risk consequence, and any per-jurisdiction overrides and role guidance authored for it. Sources at the bottom are the only citations the AI Generator is allowed to use when producing content about this field.
pep-screening · domain compliance-aml-kyc · v1
risk · criticalpublished
Definition
A check against PEP databases to determine if a customer, UBO, or related party holds (or has held) a prominent public function. PEP status mandates enhanced due diligence (EDD) for the duration of the relationship plus a cooling-off period.
Risk consequence
Onboarding a PEP without applying EDD is a significant regulatory breach. PEP exposure has been the primary driver of enforcement actions in EU AML cases since 2019.
Jurisdiction variants
| Jurisdiction | Override | Note |
|---|---|---|
| LU | — uses base definition | CSSF requires PEP screening at onboarding AND on every material change to the customer relationship (e.g. new beneficial owner, jurisdiction change). Screening must cover at least one year after the PEP leaves office. |
| EU | — uses base definition | — |
Role guidance
| Role | Guidance | Permission note |
|---|---|---|
| kyc-analyst | Run the PEP screening provider against the customer, every UBO ≥25%, and known close associates. A positive match must be confirmed by a compliance officer before onboarding proceeds. | — |
| compliance-officer | Confirm or dismiss positive PEP matches. For confirmed PEPs, document the EDD scope: source of wealth, source of funds, expected transaction profile, and ongoing-monitoring frequency. | — |
Workflow hints
| App / module | Current step | Next step | Blockers / deadline |
|---|---|---|---|
elyxen kyc / onboarding | PEP screening | Enhanced due diligence (if positive) | Cannot proceed without screening result |
Sources
AMLD5 Art. 30 Directive (EU) 2018/843 — 5th Anti-Money Laundering Directive, Article 30 (Beneficial Ownership Information) https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX%3A32018L0843 | EU | v2018 |
FATF R.12 FATF Recommendation 12 — Politically Exposed Persons https://www.fatf-gafi.org/en/publications/Fatfrecommendations/Fatf-recommendations.html | global | v2023-update |
CSSF 12/552 CSSF Circular 12/552 on central administration, internal governance and risk management https://www.cssf.lu/en/Document/circular-cssf-12-552/ | LU | v2020-revision |
Audit
Status
published
Version
1
Reviewed by
DEMO-ONLY (sample content, awaiting domain expert per KE-Q3)
Last reviewed
5/12/2026