PEP, politically exposed persons, and why status is not identity

Solidus does not ship PEP screening. It is not-built in our lexicon, along with sanctions and adverse-media screening.

What it is

A politically exposed person holds, or has held, a prominent public function, and the category usually extends to their close associates and immediate family. Heads of state, senior politicians, senior judiciary and military, senior executives of state-owned enterprises, and their circles.

PEP status is not an accusation. It is a risk classification: the position carries elevated opportunity for bribery and misuse of public funds, so the relationship warrants closer scrutiny, typically enhanced due diligence, including source-of-wealth work.

Nothing about being a PEP implies wrongdoing, and a compliance programme that treats it as a disqualification rather than a risk factor is doing it wrong.

Why it is unusually hard

Three properties make PEP screening messier than sanctions screening, which at least has defined lists:

• The population is not authoritatively defined. There is no single official register. Vendors compile lists from public sources, and coverage and thresholds differ between them.
• Status changes and persists ambiguously. People leave office. Regimes differ on how long someone remains a PEP afterwards, and whether "once a PEP, always a PEP" applies.
• Associates and family are inference. Establishing that someone is a close associate of an official is a judgement about relationships, not a lookup, and it is where false positives multiply.

Why a credential says nothing about this

Identity verification answers who someone is. PEP screening answers what position they hold and who they are connected to, facts about the world, not about the document in someone's hand.

A credential we issue is silent on the question, and no assurance level changes that. There is no angle here and we are not inventing one.

PEP data is a data business, compilation, curation, relationship inference, and keeping it current. We have none of that and are not building it. If you are evaluating PEP screening, evaluate screening vendors.

The adjacent, modest truth, the same one as elsewhere

Screening resolves better against a reliably established identity. Deciding whether a match on a common name is the right person is easier when the subject's identity was verified from a document than when it is a self-asserted name and date of birth.

We can help you be sure who you are screening. We cannot tell you whether they are a PEP, and we will not imply otherwise: a screening failure carries regulatory consequences that a marketing overstatement would not survive.

And nothing here discharges your obligation. Where a regime requires PEP identification, the duty and the evidence are yours.