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PEP and Sanctions Screening

This guide explains Politically Exposed Persons (PEP) and Sanctions screening conducted as part of identity verification through VerifiMe for AML/CTF compliance.

Edward Frame avatar
Written by Edward Frame
Updated over a week ago

Process Overview

For each client identity verification, we will:

  1. Automatically screen client details against current PEP and Sanctions lists

  2. Flag any potential matches for compliance review

  3. Conduct enhanced due diligence on flagged matches

  4. Contact clients if additional information is required

  5. Complete verification once screening is resolved

Important: This screening is a legal requirement under Australian AML/CTF laws. Being flagged does not imply wrongdoing.


Understanding Sanctions

What Are Sanctioned Entities?

Sanctions are restrictive measures imposed by individual countries (such as Australia) and intergovernmental bodies (like the United Nations) on specific organisations or individuals.

Why Sanctions Are Imposed

Sanctions address situations of international concern including:

  • Repression of human rights or democratic freedoms

  • Proliferation of weapons of mass destruction

  • Internal or international armed conflict

Types of Sanctions

Sanctions are measures "not involving the use of armed force" (UN Charter, Article 41) and may include:

  • Restrictions on economic relations and activities

  • Restrictions on goods and services

  • Restrictions on transactions with specific entities or individuals

Legal Implications

Penalties for Contravening Australian Sanctions Laws:

  • Individuals: Up to 10 years imprisonment and substantial fines

  • Corporate entities: Significant financial penalties

Application of Australian Sanctions Laws:

  • All activities conducted within Australia

  • Australian citizens operating overseas

  • Australian-registered corporations operating overseas

Note: Activities may also be subject to sanctions laws of other countries. Clients should seek legal advice to ensure full compliance with all applicable regulations.

Additional Information: Australian Sanctions Guidance


Understanding Politically Exposed Persons (PEPs)

What Are PEPs?

A Politically Exposed Person (PEP) is an individual who has been entrusted with a prominent public function. This classification is used in the financial services industry for financial crime prevention.

Who Qualifies as a PEP?

PEPs may include:

  • Members of cabinets and parliaments

  • Senior public servants and military personnel

  • Managers of state-owned companies

  • Other individuals holding prominent public positions

  • Family members and close associates of PEPs

Important Clarification

Being classified as a PEP does not imply any wrongdoing or misconduct. The classification exists because PEPs and their family members are subject to enhanced public scrutiny under financial crime laws. Enhanced due diligence on PEPs is mandated by Australian AML/CTF legislation.


VerifiMe Screening Process

Data Sources

VerifiMe maintains a commercial relationship with a specialized data provider to access comprehensive, up-to-date screening lists covering:

  • International sanctions lists (UN, EU, US, Australia, and other jurisdictions)

  • Politically Exposed Persons across all geographic regions

  • Associated individuals and entities

Screening Workflow

  1. Client details are automatically screened against current lists during identity verification

  2. Potential matches are flagged for compliance team review

  3. Enhanced due diligence is conducted on all flagged matches

  4. Clients are contacted if additional information is required

  5. Verification is completed once screening is resolved


Screening Results and Outcomes

Understanding Potential Matches

When client details match or partially match an entry on a PEP or Sanctions list:

  • This does not automatically confirm the client is the listed person

  • Common names or similar details frequently trigger false positives

  • The compliance team conducts detailed review to confirm or exclude matches

  • Resolution time varies depending on the complexity of the match

PEP Match Outcomes

If a client is confirmed as a PEP:

  • Enhanced due diligence procedures will be conducted

  • Additional documentation may be requested to verify source of funds/wealth

  • This is a standard regulatory requirement and does not imply wrongdoing

  • Verification can proceed once enhanced due diligence is completed

Sanctions Match Outcomes

If a client matches a Sanctions list:

  • The case is immediately escalated for urgent review

  • Services may be legally required to be suspended or declined

  • We are obligated to comply with all applicable sanctions laws

  • The client will be notified of the outcome as soon as possible

Note: Confirmed sanctions matches may require reporting to relevant authorities under Australian law.


Support & Questions

For questions about the VerifiMe PEP and Sanctions screening process:

Contact: VerifiMe Support Team
​Email: [email protected]

For the full list of Politically Exposed Persons across any geographic region or detailed information about specific sanctions lists, contact our support team.


Additional Resources

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