PEP screening that settles every hit with its source and ends PEP treatment the day the rules allow
Every PEP hit settled with its sources, and PEP treatment ends the day the rules allow.
See one case, screen by screen ↓PEP Screening is software for KYC teams that confirms or rules out politically exposed persons, their family members and close associates, and routes them to enhanced due diligence. Agents settle each hit with the identifier or rule that decides it, date every public role from public records and propose when PEP treatment may end. A KYC analyst records each decision and a senior manager or the MLRO approves it.
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PEP screening runs every night against lists that are broad and full of common names. Most hits are other people, or roles UK law does not count as prominent public functions: local councillors, junior officials, judges below the Supreme Court, military ranks below Lieutenant General, sporting federations. A KYC analyst clears them one by one, and the newly appointed minister with power over public procurement waits in the same queue as the namesakes.
The PEPs that are real are rarely dated. A PEP flag is set at onboarding and reviewed every two years, and nobody records when the office ended. So a former minister stays a PEP long after the 12 months the Money Laundering Regulations require, and his spouse, whose treatment should end the day he leaves office, stays a PEP family member too. Enhanced monitoring, senior sign-off and two-yearly reviews go to people the law no longer asks for, while the rule relied on, the dates, the maker and the checker live in notes.
Estimated split for one possible-PEP case at the demo bank, worked by hand and with the solution.
Seven agents rule hits out, date every public role and propose when PEP treatment ends; an analyst records and a senior manager approves.
Gareth Pryce-Whitlow, a private banking customer of Corvane Bank UK since 2019, was an MP for ten years and a junior minister until he resigned his seat in March 2025. The bank still treats him, and his wife, as PEPs. Here is what happens on the morning of Thursday, Oct 22, 2026, screen by screen, in the working solution.
Overnight the PEP data service's list update added Gareth's new board seat, and the nightly re-screen of 380,412 customers opened case HIT-26-10-0417, due Oct 28. Of 842 hits this month, the agents ruled out 760 with evidence, 41 matched known PEPs with no change, and 41 need a person, sorted by their clock. Gareth's case is first: “End PEP treatment for him and his wife”, confidence 0.96.
“4 PEPs are still treated past the date their treatment could end.”
702 hits are different people because an identifier differs: 418 because the date of birth differs. 58 hold roles that are not prominent public functions in the UK, such as 27 in local government and 5 judges below the Supreme Court, each with the paragraph of FCA guidance that excludes it. Priya checks a sample of a group, can disagree with any item, and only then confirms the group.
“A name alone never rules a hit in or out; below 0.90 the hit goes to a person.”
The agent compares Corvane's customer record with the data service profile and public records: full name, date of birth, nationality, town and dates of office. All five match and none differs, so it is the same person, with confidence 0.99.
“Same person: 5 of 5 identifiers match and none differs. Confidence 0.99.”
Member of Parliament is a prominent public function under regulation 35(14)(b), and Parliamentary Under-Secretary of State under 35(14)(a). His non-executive directorship of a private company and his charity trusteeship are not, and he is not on his party's national governing body. He is a former domestic PEP, and domestic PEPs start from a lower level of risk under regulation 35(3A).
The Tenure agent reads each role's dates from public records and draws them: MP from May 7, 2015, junior minister from Jul 9, 2024, both ending Mar 14, 2025. A treatment row shows the 12 months after he left, ending Mar 14, 2026, and 222 days treated past that date. Pins mark Appointed, Left office, 12 months end and Today, and every date opens its source.
Labels under the bar: Domestic PEP · Former · Lower-risk starting point · No higher-risk factor in 7 checks.
The agent finds his wife, Helena, among Corvane's customers. Her family-member treatment should have ended on Mar 14, 2025, the day he left office, under regulation 35(11): 587 days ago. His son is not a Corvane customer, so no action. It searched joint accounts and the persons with significant control of 2 companies; he holds 0.2% of one, and no close associates were found.
The agent runs the higher-risk indicators from FCA guidance, each with its source: wealth consistent with known sources, including a £410,000 inheritance; 41 articles since March 2025, none adverse; no power over public procurement or licenses; lower-risk products; no new public role. It proposes ending PEP treatment for him and family-member treatment for Helena today, with a senior manager's approval: confidence 0.96.
What changes: risk rating Medium 46 to Low 21, enhanced PEP monitoring rules to standard, reviews every 3 years instead of every 2.
Priya picks END-01, “12 months since leaving office, no higher-risk factor”, from 14 reason codes, adds a note, and leaves on the plain-words letter to Gareth and Helena. The decision goes to Owen Treharne, Senior Manager (MLRO delegate). Catriona Blackwood, the MLRO, is informed in her monthly report.
The person who records a decision can never approve it.
Owen approves. The client lifecycle management system and the core banking system take the change: both PEP flags end, the risk rating falls from Medium 46 to Low 21, monitoring returns to standard rules, and the next review moves to Oct 2029. Screening carries on every night, and the record of his PEP status is kept.
“If he takes a public role again, the Tenure agent reopens the case.”
Dominic Harcastle-Reid became Minister of State for Defence Procurement in the reshuffle of Oct 19, with influence over equipment programs worth about £14 billion a year. Responsibility for large public procurement is a higher-risk indicator, so the lower-risk starting point gives way: the agents propose higher-risk treatment and the MLRO's approval, and Priya sends the hand-off to Nadia Kershaw in EDD.
EDD must establish: source of wealth with evidence, the source of the £1.2 million deposit of Aug 2026, and his declared interests.
The same PEP screening case, seen by the five people who carry it: what their week looked like, and what it looks like now.
Seven agents rule hits out, date every public role and propose when PEP treatment ends; an analyst records and a senior manager approves.
Takes every hit and trigger from the PEP data service, opens a case with its clock, runs the agents in order and routes the case to a KYC analyst.
Compares date of birth, full name, nationality, residence and dates of office, and names the identifier that rules a hit out.
Tests every listed role against regulation 35(14) and the thresholds in FCA guidance FG25/3, and classifies the PEP as domestic or foreign.
Records each role with its dates from parliament, appointment and company records, works out when treatment may end for each person, and watches elections, reshuffles and list updates.
Finds family members, close associates and PEP-controlled companies among the bank's customers, and sets each one's own end date.
Starts domestic PEPs from lower risk, runs the higher-risk indicators, and proposes the measures, the approver and the review cycle.
Keeps the sources, decisions and approvals on the case, writes the audit trail and builds redacted export packs.
Records with a reason; a senior manager approves. The agents propose; a named person decides.
Beside every case, ask about any person, role, end date or rule. Every answer points to its source.
Why can PEP treatment end now?
He left both offices on Mar 14, 2025. The Regulations require at least 12 months after that, which ended Mar 14, 2026. A longer period is only for PEPs assessed as higher risk, with the reason written down; none of the 7 higher-risk checks found anything. Your Standard ends treatment at 12 months in that case.
Has he taken any new public role?
No. Since leaving he became a non-executive director of a private company, Harlow Fenwick Engineering plc, on Jun 2, 2025, and a charity trustee in Jan 2026. Neither is a prominent public function. He is not on his party's national governing body. The Tenure agent keeps watching appointments and elections.
What happens to Helena's record?
Her family-member treatment should have ended on Mar 14, 2025, the day he left office; it has run 587 days since. The proposal ends it today in the same decision, with reason END-02. She keeps standard due diligence and screening.
Why was a county council leader ruled out?
Because local government in the UK is not a prominent public function: FCA guidance says the definition does not include it, and Corvane's Standard uses no wider categories. This month 27 local-government hits were ruled out on that basis, and an analyst checked a sample before confirming the group.
13 screens from the working solution, on its sample data. Pick one to see it large.
What the bank decides for itself are settings. Every change is proposed by the administrator, approved by the MLRO and kept on the trail; legal floors are locked and say why.
| Setting | Default | Choose from |
|---|---|---|
| Armed forces: the lowest rank treated as a PEP | Lieutenant General or equivalent | Lieutenant General or equivalent · Major General or equivalent |
| State-owned enterprises: the state's share | Over 50% | Over 50% · Over 25% |
| A PEP after leaving office | At least 12 months | Locked by regulation 35(9); longer only with a written higher-risk rationale and the MLRO's approval |
| Approver for a lower-risk domestic PEP | Senior Manager (MLRO delegate) | Senior Manager (MLRO delegate) · MLRO |
| Approver for a foreign PEP, or any higher-risk factor | MLRO | MLRO · Senior Manager (MLRO delegate) |
| Clock for a new PEP or connection | 5 business days | 3 · 5 · 10 business days; escalate to the team lead at 80%, to the MLRO when late |
| Lowest confidence at which an agent may rule a hit out | 0.90 | 0.85 · 0.90 · 0.95; below it, a person decides |
| Sample of identity rulings checked by people | 5% | 3% · 5% · 10% |
Every figure is labelled: a target the solution is built to, an estimate, a typical published result, or a proven one.
“demo” = seen in the working solution, on its sample data · “target” = the design goal, measured in the live solution · “estimated” = our estimate of where an analyst's hours go on one case · “typical” = screening false-positive rates as commonly reported by industry sources, directional. Rules referred to: Money Laundering Regulations 2017, regulations 35 and 40 (legislation.gov.uk); FCA FG25/3, The treatment of politically exposed persons for anti-money laundering purposes (Jul 2025, fca.org.uk). The bank, people, companies, constituencies and customer numbers named on this page are fictional: characters and sample data in the working solution.
PEP Screening is software for KYC teams that confirms or rules out politically exposed persons, their family members and close associates, and routes them to enhanced due diligence. Agents settle each hit with the identifier or rule that decides it, date every public role from public records and propose when PEP treatment may end. A KYC analyst records each decision and a senior manager or the MLRO approves it.
Under the UK Money Laundering Regulations, a PEP is treated as one for at least 12 months after leaving a prominent public function, and longer only if the bank assesses them as higher risk and writes down why. Family members and close associates are treated as ordinary customers from the day the PEP leaves office. The Tenure agent works out each person's date and opens a case on the morning treatment may end.
The Identity agent rules a hit out only with the identifier that differs, such as a date of birth or a nationality; a name alone never rules a hit in or out. The Public role agent rules out roles UK law does not count, such as local government, citing the paragraph of FCA guidance that excludes them. Below 0.90 confidence a person decides, and analysts check a sample of every group before confirming it.
Yes. The Family and associates agent searches joint accounts, ownership registers and relationships for family members and close associates among the bank's customers, each with their own end date. A company is treated with PEP measures only where the PEP has significant control: in the working solution, a 40% owner and director brings PEP measures, and the company's other owners are not treated as associates.
Domestic PEPs start from a lower level of risk; a higher-risk indicator, such as responsibility for large public procurement, changes that. The Treatment agent then proposes higher-risk treatment, MLRO approval and a hand-off to an EDD specialist listing what must be established, such as source of wealth with evidence, the source of funds for a large deposit and declared interests, each with a due date.
Not on PEP status alone: that rule is locked in the settings, and a decline needs the risk that cannot be managed. Letters to customers use plain words and never call them high risk, and relationship managers see only whether a customer is a PEP and the next review.
Yes. The agents propose, explain and cite; they never approve, decline, end treatment, change a customer record or send a letter. A KYC analyst records each decision with a reason code, a second person approves it, and an analyst who disagrees with the agents records an override with a reason that is reported to the MLRO.
The Agentic Solution Engine builds and deploys it from your requirements and documents: your PEP Standard, approval rules, queues and a sample of past PEP hits. It goes live once every quality gate has passed. We will walk you through it on your own PEP hits first.
Every blocked share traced to its source; the 50% call made while the payment is held.
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1-min demoSanctions Alert ReviewEvery hit cleared identifier by identifier; true matches with the officer within the hour.
1-min demoWe'll run PEP Screening on a sample of your own PEP hits and relationships.