PEPs, Sanctions & High-Risk Clients
Screening obligations and escalation
What is a PEP?
A Politically Exposed Person is anyone entrusted with prominent public functions — heads of state, government members, senior judges, central bank officials, ambassadors, senior military officers and senior executives of state-owned enterprises.
Family members and associates
PEP status extends to immediate family members (spouses, children, parents) and known close associates. Treat them with the same enhanced scrutiny.
Sanctions screening
Screen all clients and UBOs against EU consolidated sanctions lists, UN sanctions and OFAC where relevant. A sanctions hit is non-negotiable: stop the transaction and escalate immediately.
High-risk jurisdictions
Apply EDD when clients, funds or counterparties are connected to FATF grey/black-listed jurisdictions or countries with weak AML controls.
Adverse media
Negative news linking a client to fraud, corruption, money laundering or organised crime is a serious red flag — even without a formal sanction.
Why escalation matters
Never resolve a PEP, sanctions or adverse media hit alone. Escalate to your compliance officer or MLRO so the case can be properly assessed and documented.
Official sources for this module
Primary publications from SEPBLAC and the Spanish Tesoro underpinning the material above.
- SEPBLACPDFGuía orientativa sobre riesgo geográfico
How to weigh country risk when a client, UBO or counterparty is linked to a specific jurisdiction.
See the full list on the Sources page.