A PEP flag means Workflow found a potential name match against a global database of politically exposed persons. It does not mean the check has failed, most PEP flags are false positives and are straightforward to resolve.
What is a PEP?
PEP stands for Politically Exposed Person. The term refers to individuals who hold or have held prominent public positions, such as senior politicians, government officials, judges, senior military officers, or executives of state-owned enterprises. Their immediate family members and close associates may also be classified as PEPs.
AML law requires that PEPs be treated as higher-risk clients due to the potential for corruption or misuse of public funds. The check is standard and it doesn't reflect any suspicion about your specific client.
Why PEP flags are often false positives
Workflow's PEP database matching is intentionally broad. It flags potential name matches, not confirmed matches. A common surname, a name that matches a minor public official in another country, or a name shared with a former politician can all trigger a flag.
This is by design, it is better for the system to flag and have you review it than to miss a genuine match.
What to do when you receive a PEP flag
Click Download Report from the verification result screen to view the full verification report
Open the report and review the PEP match details, the report will show you who was matched and why
Compare the match details against what you know about your client such as their name, age, country, occupation
If the match does not relate to your client, return to the case and open the Notes tab
Add a note explaining your review when you mark the client verification as a pass— for example: "PEP flag reviewed. Match is for [Name], a former politician in [Country]. Client is a [occupation] based in [City]. Not the same individual."
Your reasoning is now part of the audit trail. An auditor reviewing the case will see both the flag and your documented response.
What if the PEP match does relate to my client?
If you believe the match is genuine and that your client is or was a politically exposed person then you simply treat them as a higher-risk client. This means:
Completing a thorough risk assessment, known as Enhanced Due Diligence (EDD)
This involved collecting source of funds documentation or source of wealth documentation. Upload this to the client risk assessment documents section
Contact APLYiD support if you're unsure how to proceed in this situation.
What about adverse media flags?
Workflow may also flag adverse media, news or public records associated with your client's name. Workflow only surfaces adverse media that specifically relates to money laundering, financial crime, or terrorism financing. General negative press (disputes, complaints, civil matters) is not flagged.
If adverse media is flagged:
Download the report and review the specific media reference
Assess whether it relates to your client and whether it is credible and relevant
Document your review and conclusions in the Notes tab
Proceed accordingly — if genuinely concerning, treat the client as higher risk
Do PEP and adverse media flags automatically change the risk level?
A flag does not automatically change the risk outcome. However, if you confirm the match is genuine, it should be reflected in your risk assessment. Answer the relevant risk assessment questions accordingly as this will influence the calculated score.
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This article provides general information only and is not legal advice.