Evaluation guide
Turn a PEP Finding into a Reviewable Decision
Evaluate PEP screening by the evidence it gives your reviewer and how well your team can document a decision.
Prepared by CirclesCheck · Updated . Product evaluation guidance; independent regulatory review is not claimed.
Inspect the source record
Review the role, jurisdiction, source, and available dates. Confirm the identifiers that connect a record to the customer rather than relying only on a similar name.
Clarify coverage
Ask which jurisdictions and connected-person categories are included, how they are sourced, and when each dataset was updated. A total database size does not establish coverage for your business.
Follow your review policy
Define how a potential PEP finding is assessed and escalated. A PEP finding should prompt your review process; it does not by itself decide whether to accept the customer.
Keep the reasoning
Record the evidence compared, decision, reviewer, and any follow-up work. Revisit the customer when your monitoring workflow surfaces a material change.
Evaluate the workflow
Use your organization's policy and applicable official guidance to decide the controls you need. This article describes a product evaluation workflow, rather than a regulatory determination.