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Understanding PEP, Sanctions and Adverse Media Checks

APLYiD screens your client's name and date of birth against three types of database:

  • PEP (Politically Exposed Persons): people who hold, or have held, a prominent public role, and their close family and associates.

  • Sanctions: people and organisations on government sanctions lists.

  • Adverse media: negative news coverage linked to financial crime or other serious wrongdoing.

Which checks include screening

Check

Includes PEP, sanctions and adverse media?

Where to find results

Biometric + AML Check

Yes

Open the verification in Biometric > Completed > APLYiD/AML Check tab

Standalone PEP check

Yes. You'll need your client's full name and date of birth.

PEP > Completed, then download the report

Manual verification

Yes

Manual > Completed

What the results mean

Result

What it means

Pass

No match was found for your client.

Fail

A possible match was found. Review it before you proceed.

A match doesn't mean your client is that person, or that they're high risk. It means their details are similar enough that someone needs to check.

In a verification, a possible match sends the verification to Review.

Why matches happen

These databases hold millions of records, and matches are based on name and date of birth, not a unique identifier like a passport number. Clients with common names are matched more often.

Small differences in the details you enter can change the result, so enter them exactly as they appear on your client's ID. A standalone PEP check needs your client's full name and date of birth. Including a middle name can make the search more specific.

How to review a match

  1. Log in to the APLYiD Core portal.

  2. Open the completed check (see the table above for where to find it).

  3. Check the result. For a verification, look at PEP sanctions and adverse media clear on the APLYiD/AML Check tab. For a standalone PEP check, download the report from PEP > Completed.

  4. Review the match details, such as name, nationality, date of birth and role.

  5. Compare them with what you know about your client. Look for clear differences, such as:

    • a different date of birth

    • a different middle name

    • a different nationality or country of residence

    • a different occupation or public role

    • the matched person is deceased or from a different era

  6. Record why you've ruled the match in or out, and keep the report in line with your AML/CFT programme.

If there's a clear difference, the match is almost certainly a false positive.

If you're not sure

If the match details are limited and you can't rule the match out, don't dismiss it. Instead:

  • Ask your client whether they've held a public office or government role, or are subject to sanctions.

  • Do your own open-source search, for example on Google or LinkedIn.

  • If you still can't rule it out, treat the client as higher risk and apply enhanced due diligence, such as source of funds and additional identity checks.

If you have reasonable grounds to think the match is genuine, contact your AML/CFT Compliance Officer straight away, and don't proceed with the transaction until it's resolved.

What not to do

  • Don't dismiss a match without reviewing it. Undocumented decisions are a compliance risk.

  • Don't tell your client if you've made, or are considering, a suspicious activity report. This is tipping off, which is prohibited under AML/CFT law.

  • Don't rule a match out because your client seems trustworthy. Base your decision on evidence.

This article is general guidance only and is not legal advice.

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