PEP red flags: 7 indicators for suspicion

Many uncertainties and misunderstandings surround politically exposed persons (PEPs). Classifying a client as a PEP is part of the process that enables financial institutions (FIs) and designated non-financial businesses and professions (DNFBPs) to assess the risks related to PEPs.

Since 2012, the United Nations Convention against Corruption (UNCAC) Article 52 has significantly impacted FIs’ identification and management of PEPs. This article requires enhanced due diligence (EDD) for PEPs, meaning stricter background checks, verification of wealth sources, and close monitoring of transactions for suspicious activity, expanding on previous regulations by including foreign PEPs and domestic officials, their families, and close associates. 

Of course, being a PEP does not equate to being a criminal or suggest a link to abuse of the financial system. However, as PEPs are higher-risk customers, FIs and DNFBPs must be familiar with the PEP red flags and indicators used to detect such abuse. 

What are 7 PEP red flag indicators?

The Financial Action Task Force (FATF) has developed a list of PEP red flags/indicators to assist in detecting misuse of the financial system by PEPs during a customer relationship. 

Often, matching one or two of these indicators indicates a statistically raised risk of doing business with a particular customer, and several indicators need to be met before grave suspicion is warranted. However, in some cases – depending on specific circumstances – matching just one or more of these indicators could lead directly to suspicion of illegal activity, such as money laundering.

The FATF’s recommended red flags, as outlined in recommendations 12 and 22, are as follows:

 1. PEPs attempting to shield their identity

PEPs know their status may facilitate the suspicion of illicit behavior. With that in mind, they may conceal their true identity through various means to avoid detection, protect unearned assets, or evade legal trouble. Under the FATF’s recommendation, some of the key red flags to watch out for include the following:

• The use of corporate vehicles to obscure (i) ownership, (ii) involved industries, or (iii) countries.
• Use of corporate cars without a valid business reason.
• Use of intermediaries that don’t match with everyday business practices
• Use of PEP relatives and close associates (RCAs) as legal owners.

2. Suspicious behavior from PEPs 

When liaising with entities and monitoring activity, firms need to stay vigilant regarding a PEP’s movements and general behavior.  In particular, firms should be aware of any unusual inquiries about their AML/CTF policies, alongside uncommon transfers to accounts in different countries. As a result, the FATF encourages firms to monitor the following: 

• Investigate any inconsistencies between the information provided by entities and publicly available data, such as asset declarations or salaries, as these discrepancies could warrant further investigation.
• Pay close attention to entities conducting business in your jurisdiction without a clear and justifiable reason – a legitimate business purpose should be readily available.
• Carefully scrutinize entities that provide inaccurate or incomplete information, as deliberate misinformation is highly suspicious and requires further investigation.
• Entities who inquire about a firm’s AML/PEP policies, which could signal potential attempts to exploit vulnerabilities.
• Be cautious of entities seeking services they wouldn’t usually require, as this might suggest attempts to hide assets.
• Monitor entities who frequently transfer funds to countries with no apparent connection, as these unrelated financial activities raise concerns about potential illicit sources of income.
• Conduct additional due diligence for entities denied a visa to your country, as entry restrictions might suggest past issues or security concerns.
• Closely monitor entities from countries with restrictions on foreign account ownership, as country-specific limitations on holding accounts can be a risk factor.

3. The PEP’s position or involvement in business 

While the previous section highlighted behavioral red flags, understanding a PEP’s position and power within their organization adds another crucial layer to the risk assessment. As outlined by the FATF, individuals holding roles with greater control, authority, and influence can be inherently more susceptible to involvement in illegal activities. Here’s why: 

• Substantial authority over or access to state assets, funds, policies, and operations.
• Control over regulatory approvals, including awarding licenses and concessions.
• The formal or informal ability to control mechanisms established to prevent and detect money laundering and terrorist financing (ML/TF).
• If they (actively) downplay the importance of their public function or the public function they’re associated with.
• The PEP does not reveal all positions (including ex officio).
• Access to or control or influence over government or corporate accounts.
• Own or control financial institutions or DNFBPs, either privately or ex officio.
• The PEP (partially) owns or controls the financial institution or DNFBP (privately or ex officio) that is a counterpart or a correspondent in a transaction.
• The PEP is a director or beneficial owner of a legal entity that is a client of a financial institution or a DNFBP.

4. High-risk industries and sectors for PEPs 

Alongside the PEP’s position in their organization, connections with high-risk industries can raise their risk level. FIs and DNFBPs should use national guidance and conduct thorough risk assessments per the FATF’s recommendation 1. While high-risk industries will indubitably vary from country to country, the FATF presents the following as examples of higher-risk sectors in its recommendations 12 and 22:

• Arms trade and defense.
• Banking and finance.
• Businesses active in government procurement (i.e., those whose business is selling to government or state agencies).
• Construction and (extensive) infrastructure.
• Development and other types of assistance.
• Human health activities.
• Mining and extraction.
• Privatization.
• Provision of public goods and utilities.

5. Transaction indicators 

Accurate transaction monitoring is essential as a PEP’s transactions and banking history can reveal a complete overview of their income, spending, and saving activity for any period. The purpose of a transaction, as well as the nature of the business relationship behind it, should be scrutinized, along with the examples below:

• Private banking.
• Anonymous transactions (including cash).
• Non-face-to-face business relationships or transactions.
• Payments received from unknown or unassociated third parties.
• Using several separate bank accounts for unknown purposes.
• Consistent use of rounded amounts that can’t be justified.
• An account shows a sudden flurry of activity after a dormant period.

6. Products, services, and delivery channels red flags 

Another key indicator, depending on the nature of the PEP, is their connection to certain industries, products, services, transactions, or delivery channels that can be labeled as high-risk and easy to exploit for money laundering or other illicit purposes. Some of these include:

• Businesses that mainly cater to (high-value) foreign clients.
• Trust and company service providers.
• Correspondent and concentration accounts.
• Dealers in precious metals, precious stones, and other luxurious goods.
• Dealers in luxurious transport vehicles (such as cars, sports cars, ships, helicopters, and planes).
• High-end real estate dealers.

7. Country-specific PEP red flags and indicators

As defined by the FATF in recommendation 19, due diligence is vital if a foreign or domestic PEP is from a higher-risk country. Additionally, the FATF also recommends taking the following geographical considerations into account when entering into a business relationship with a PEP: 

• Foreign or domestic PEPs from countries that have yet to sign or ratify relevant anti-corruption conventions (or otherwise have not or have only insufficiently implemented these conventions), such as the UNCAC and the OECD Anti-Bribery Convention.
• Foreign or domestic PEPs from countries with mono-economies (economic dependency on one or a few export products), especially if their countries have export control or licensing measures.
• Suppose a PEP from a high-risk country has control or influence over decisions that aim to address any shortcomings in the anti-money laundering and combating the financing of terrorism (AML/CFT) system. In that case, it can lead to additional risks.
• Foreign or domestic PEPs from countries that depend on the export of illegal substances, such as narcotics.
• Foreign or domestic PEPs from countries with high levels of organized crime.

Detect red flags with automated solutions 

With so many red flags to be wary of, manually analyzing a PEP’s financial transactions, wealth sources, and business relationships can be time-consuming and prone to human error. 

Fortunately, advanced AML solutions offer sophisticated tools that empower comprehensive EDD for PEPs. These solutions surpass basic EDD by delving deeper into their finances and finding the true nature of wealth and transactions. 

Even after initial due diligence, continuous monitoring remains crucial – dynamic screening tools can provide a safeguard by automatically monitoring transactions and activities for suspicious patterns or red flags that may indicate money laundering or other financial crimes.

Implementing these solutions can offer significant advantages – streamlined data analysis and automated workflows significantly reduce operational burdens, freeing up resources for your team to focus on strategic tasks.