Watchlist Search
PEP Lists
Quick answer. A politically exposed person is someone a policy treats as higher risk because of a public role. PEP status is not, by itself, an OFAC block. A watchlist search only means something after you name the list. OFAC’s Sanctions List Search covers the SDN list and other OFAC lists. UN, EU, and UK lists are different publications. A PEP file is not a sanctions list.
Official office
Office of Foreign Assets Control
Steps
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Screen OFAC first for a U.S. question
Use the official search or the current SDN file from the Sanctions List Service.
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Add the other lists your policy names
UN, EU, and UK are separate downloads and separate hits.
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Treat PEPs as a policy category
There is no single official U.S. PEP list. Cite the role and the source.
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Compare identifiers
A similar name is not the listed person until date of birth, address, or ID fails to distinguish them.
PEPs are not a sanctions list
There is no single official United States PEP list comparable to the SDN list. Commercial PEP files disagree with each other. Cite the source and the role, and say when the role ended if the source says so.
Screen PEPs because your policy says to, and screen sanctions lists because the law says to. Do not merge the two labels.
Name the list before you report a hit
Search OFAC at sanctionssearch.ofac.treas.gov. Record the confidence setting, the program code, and the date. OFAC says the tool is not a substitute for due diligence and will not pick the threshold for you.
A government watch list search that dumps every commercial file into one red flag hides the source. Keep OFAC, UN, EU, UK, and PEP in separate lines of the note.
Common mistakes
- Calling a UN hit an OFAC hit.
- Calling a PEP a sanctions target.
- Hiding the match threshold.
- Using a stale SDN file.
Questions
Where is the official OFAC search?
sanctionssearch.ofac.treas.gov. Data files are on OFAC’s Sanctions List Service.
Is the FBI watch list the SDN list?
No. Do not substitute one government list for another. Screen the list your policy names.
What should I record?
The name you typed, the date, the list, the program code, and how you compared identifiers.