Why PEP Screening Matters for Accountants & Bookkeepers
Understand PEP checks, risk and EDD. Learn how FigsFlow automates PEP screening and compliance.
In the dynamic landscape of financial regulation, UK accountants and bookkeepers face an ever-evolving set of responsibilities, particularly concerning Anti-Money Laundering (AML) compliance. A critical component of this is PEP screening, a process designed to identify and mitigate risks associated with Politically Exposed Persons (PEPs). The year 2026 brings significant updates to the regulatory framework, emphasising a more proportionate, risk-based approach while strengthening defences against financial crime.
This section provides a comprehensive overview of what constitutes a PEP, the inherent risks they present, and the specific AML compliance requirements for UK accounting professionals. We will delve into the latest guidance from key regulatory bodies such as HMRC, the Financial Conduct Authority (FCA), ICAEW, AAT, and ICB, ensuring you have the most up-to-date information to navigate the complexities of PEP screening effectively.
Key Points Summary
Understanding PEPs – Individuals in prominent public positions (UK or abroad) who present higher money laundering risks due to their influence and access.
Three Risk Categories – Domestic PEPs are now lower risk unless other factors exist; Foreign PEPs from high-risk jurisdictions require Enhanced Due Diligence; International PEPs depend on their organisation.
2025 Regulatory Shift – The FCA’s FG25/3 guidance emphasises proportionate, risk-based approaches rather than blanket high-risk treatment for all PEPs.
Enhanced Due Diligence Requirements – Source of wealth verification, source of funds documentation, senior management approval, and ongoing monitoring for high-risk PEP relationships.
Automation is Essential – Manual PEP checking is error-prone and time-consuming. Modern software provides real-time screening, ongoing monitoring, and comprehensive audit trails.
Integration Matters – Embedding PEP checks into your client onboarding workflow through API connections streamlines compliance and improves efficiency.
What Exactly is a Politically Exposed Person?
A Politically Exposed Person (PEP) is an individual entrusted with prominent public functions, either in the UK or elsewhere. Due to their position and influence, PEPs can be susceptible to corruption, bribery, and other illicit activities, making them a higher risk for money laundering and terrorist financing.
For accountants and bookkeepers, accurately identifying and assessing the risks associated with PEP clients is fundamental to robust AML compliance.
What is a PEP?
A Politically Exposed Person (PEP) is an individual who holds, or has held, a prominent public position or function. This includes heads of state, senior politicians, senior government, judicial or military officials, senior executives of state-owned corporations, and important political party officials. The definition also extends to their immediate family members and close associates, who may be used to conceal illicit funds.
The inherent PEP risks stem from the potential for their position to be abused for private gain, either directly or through their connections. This can manifest as bribery, embezzlement, or the use of their influence to facilitate money laundering. Accounting professionals must be vigilant in identifying these risks, particularly when dealing with complex financial structures or transactions that appear inconsistent with a client’s known legitimate income or business activities.
The Three PEP Categories You Need to Know
Understanding the different PEP categories is crucial for applying a proportionate risk-based approach. The 2025 regulatory updates, particularly the FCA’s Finalised Guidance FG25/3, have provided important clarifications on how these categories should be assessed.
- Domestic PEPs – These are individuals holding prominent public positions within the UK. Historically, all PEPs were treated with a high level of scrutiny. However, the revised 2025 guidance clarifies that Domestic PEPs should generally be treated as lower risk, unless other specific risk factors (unrelated to their PEP status) are identified. This allows for a more nuanced and proportionate approach to UK-based public officials. Examples include senior politicians, judges, high-ranking civil servants, and military officers.
- Foreign PEPs – These are individuals who exercise prominent public functions outside the UK. Due to varying levels of corruption and governance in different jurisdictions, Foreign PEPs typically warrant a higher-risk classification. Enhanced Due Diligence (EDD) is particularly important for PEPs from countries identified by the Financial Action Task Force (FATF) as “Call for Action” jurisdictions.
- International PEPs – This category includes individuals who hold prominent positions in international organisations, such as directors, deputy directors, or members of the board of international bodies. The risks associated with International PEPs are assessed based on the specific organisation and the individual’s role.
The regulatory framework also extends to family members and close associates of PEPs, as they can be used to facilitate illicit activities. Firms must assess the actual risk posed by these individuals rather than applying an automatic high-risk classification.
| PEP Category | Typical Risk Level (2025) | Key Considerations for Accountants |
|---|---|---|
| Domestic PEPs (UK) | Lower (unless other risks) | Apply proportionate scrutiny; focus on non-PEP related risk factors. |
| Foreign PEPs (Increased Monitoring Countries) | Medium | Standard EDD, but not automatic high-risk. |
| Foreign PEPs (FATF Call for Action Countries) | High | Mandatory EDD, rigorous source of wealth/funds checks. |
| Family Members & Close Associates of PEPs | Risk-dependent | Assess actual risk, not automatic high-risk. |
Run your firm on one platform
Proposals, engagement letters, pricing and AML — built for ACCA, ICAEW, ATT, CIOT, AAT and CIMA firms.