Solution · PEP Screening

PEP Screening, Tiered Risk Classification & RCA Coverage

One Constellation identifies politically exposed persons, their relatives and close associates across every jurisdiction — with tiered risk classification, automated periodic refresh, and PEP definitions aligned to FATF, MAS, FCA and FinCEN.

The Challenge

Identifying PEPs Is Easy. Classifying Them Correctly Is Hard.

Every major AML regime requires enhanced due diligence on politically exposed persons — and on their immediate family members and close associates. The principle is simple: customers with public-function influence carry elevated bribery and corruption risk. The execution is anything but.

PEP definitions vary by regulator. The FATF baseline differs from MAS guidance, which differs from the FCA's risk-based interpretation, which differs from FinCEN's narrower scope. Tier-1 heads of state are obvious; tier-3 municipal officials and the cousin of a former minister are not. And every PEP status decays over time — a former minister remains a PEP for a defined window under most regimes, but how long, and from when?

One Constellation handles PEP screening as a structured, jurisdiction-aware capability. Customers are matched against a curated PEP database with tier-1 through tier-4 classification, RCA linkages mapped to the source PEP, and rule-based status decay applied automatically. Every match is dispositioned with full evidence — and refreshed on the schedule each regulator expects.

How It Works

PEP Screening Built Around How Regulators Actually Define the Risk

Tiered classification

PEP matches are returned with a defined classification tier — foreign heads of state (tier 1), senior government officials (tier 2), middle-rank officials (tier 3), and state-owned enterprise executives (tier 4) — aligned to your jurisdiction's specific definition.

RCA mapping

Relatives and Close Associates are flagged with the source PEP linkage visible — the customer's wife who is herself an RCA of a foreign senior official surfaces with that exact relationship, not as a generic match.

The point of PEP screening is not to find PEPs. It's to apply the right level of due diligence to the right tier of PEP — and to keep doing it for as long as the regulator says you should.
— Design principle, One Constellation PEP engine
Operational Impact

PEP Screening, Measured

Performance figures from production deployments of One Constellation PEP screening.

3M+
PEP & RCA Profiles in Database
4
Risk-Tier Classification Levels
240+
Jurisdictions Covered
Auto
Periodic Refresh Workflows
Daily
Database Update Cycle
What's Included

End-to-End PEP Capability — Not Just a Match API

PEP screening on One Constellation covers identification, classification, RCA mapping, periodic refresh and EDD workflow triggers — all in a single capability.

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Onboarding PEP Check

Every new customer is screened against the PEP database at onboarding, with tier classification and RCA linkage returned in real time.

Explore Onboarding →
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Periodic Refresh

Customer PEP status is refreshed automatically on the schedule each regulator requires — annually, semi-annually or risk-triggered.

Explore Portal →
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EDD Auto-Triggering

A confirmed PEP match automatically routes the customer into the appropriate EDD workflow with Source of Funds and Source of Wealth requirements pre-set.

Explore AML/CFT →
Capabilities

Everything a Defensible PEP Programme Requires

PEP screening is one of the areas regulators scrutinise most closely — for good reason. Get the tiering wrong, miss an RCA, fail to refresh, and the audit finding writes itself.

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Tier 1–4 Classification

Every PEP match is returned with a defined risk tier aligned to your jurisdiction's regulatory definition — not a generic "PEP yes/no" flag.

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Relatives & Close Associates

Spouses, children, parents, in-laws and known close business associates of PEPs are mapped to the source PEP with relationship type preserved.

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Status Decay Rules

Former PEP status is tracked per regulator's defined window — typically 12 months post-leaving public function, with risk-based extension supported.

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Jurisdiction-Aware Definitions

Foreign vs domestic PEP distinction handled automatically, with country-specific definitions applied (e.g. MAS's broader scope vs FinCEN's narrower one).

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Match Evidence

Every match returns the source data, public role, jurisdiction and tenure dates — analysts disposition with evidence, not just a name match.

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Continuous Re-Screening

Customers re-screened on every database update — newly identified PEPs surface against your existing customer base automatically.

Regulatory Alignment

Aligned to the PEP Definitions Each Regulator Actually Uses

PEP definitions and EDD obligations differ materially between regulators. One Constellation supports the specific definition each regime applies to your customer base.

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FATF Recommendation 12
Foreign PEPs & Family Members
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MAS Notice 626
Singapore PEP Requirements
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FCA SYSC 6.3
UK PEP Risk-Based Approach
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FinCEN CDD Rule
US Senior Foreign Political Figures
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EU 6AMLD
PEP & Family Member Definitions
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HKMA AMLO
HK PEP & Connected Persons
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AUSTRAC PEP
AU Domestic & Foreign PEPs
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DFSA Module AML
UAE PEP & RCA Standards
Part of the Platform

PEP Screening, Wired Into the Customer Lifecycle

PEP status isn't a one-time flag. It's a continuous attribute of the customer record that drives risk scoring, EDD frequency, transaction-monitoring thresholds and periodic review cadence — across every system that touches the customer.

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Integrated With
CRA · EDD · Periodic Review

When a PEP match is confirmed, the customer's risk score updates, the EDD workflow auto-initiates with Source of Funds and Source of Wealth requirements, the transaction-monitoring profile tightens, and the periodic review cadence shortens — all without any manual orchestration.

The result is a PEP programme that doesn't just identify PEPs but actually applies the heightened due diligence the regulation requires — visibly, consistently and provably.

PEP Screening FAQ

What Compliance Teams Ask Us

How does One Constellation classify PEP risk tiers?+
We apply a four-tier classification: Tier 1 (foreign heads of state, senior politicians, top judiciary, military), Tier 2 (senior officials of foreign governments and state-owned enterprises), Tier 3 (middle-rank officials, senior diplomats, sub-national politicians), and Tier 4 (state-owned enterprise senior management and senior officials of major international organisations). Tier definitions are adjustable to your jurisdiction's specific framework.
How are Relatives and Close Associates (RCAs) identified?+
RCAs are sourced from the same curated database that maintains the PEP profiles, with explicit relationship mapping (spouse, child, parent, sibling, business partner, known associate). Every RCA match surfaces with the source PEP linkage and relationship type.
How long does someone remain a PEP after leaving public function?+
The default rule is 12 months following the end of the public function, in line with most major regulators including MAS, FCA and FATF. The platform supports configurable extension on a risk-based approach where the customer's residual influence justifies it — and some regulators require longer or indefinite retention.
How often is the PEP database updated?+
The PEP database is updated daily, with material events (cabinet appointments, elections, resignations) typically reflected within 24 hours of public confirmation. Your customer base is automatically rescreened against database updates.
Does the platform handle domestic vs foreign PEP distinction?+
Yes. Customer location and PEP jurisdiction are both held in the record, and the foreign/domestic distinction is applied automatically. This matters in jurisdictions like the US (FinCEN focuses on senior foreign political figures) but less so in jurisdictions like Singapore (MAS treats domestic and foreign PEPs as broadly equivalent).
Can we tune PEP match thresholds by customer segment?+
Yes. Match thresholds are configurable per customer book — for example, a private banking unit may want stricter (lower-threshold) matching for HNWI customers than a mass-retail division applies. Every threshold is logged and exportable for audit.

Apply the Right EDD to the Right PEP.

See how One Constellation handles PEP screening, tiering and RCA mapping for regulated firms across 15 jurisdictions — with the audit trail every regulator expects.

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