Sanctions List & PEP Screening

Sanctions violations can lead to fines, criminal proceedings and considerable reputational damage. We help you screen customers and business partners reliably against sanctions lists and for PEP status – with a process that suits your business.

Sanctions lists: mandatory for every company

EU financial sanctions apply directly in all member states. Funds and economic resources of listed persons and organisations must be frozen; no funds or economic resources may be made available to them, directly or indirectly (prohibition on making funds available). This applies not only to banks but to every company – regardless of whether it is an obliged entity under the German Anti-Money Laundering Act.

Politically exposed persons (PEPs)

Obliged entities under the GwG must use appropriate, risk-based procedures to determine whether their customer or its beneficial owner is a PEP, a family member or a known close associate. In this case, enhanced due diligence applies (Section 15 GwG), including:

Approval of the business relationship by a member of senior management
Appropriate measures to establish the source of wealth and funds
Enhanced ongoing monitoring of the business relationship

PEP status continues for at least twelve months after leaving office.

Our services

Screening concept

Who is screened and when? Onboarding, ongoing screening, event-driven checks – matched to your risk.

Tool selection

Independent support in selecting and setting up suitable screening solutions or databases.

Handling hits

Clear rules for reviewing name matches, escalation and approval.

Documentation

Evidence of every check and every decision – filed in an audit-proof way.

If there is a true match

Do not provide any serviceIn the event of a confirmed sanctions match, do not make any funds or goods available.
Escalate internallyInvolve the AML officer or management immediately.
Inform the authoritiesDepending on the case, report to the competent bodies (e.g. Deutsche Bundesbank for financial sanctions) and, if applicable, file a suspicious activity report with the FIU.
DocumentRecord the match, the review and the decision in a traceable way.

Tip: A simple name search is often not enough. Effective screening takes spelling variants, dates of birth and ownership into account – companies owned or controlled by listed persons may also be affected.