Entity Screen
PEP Screening
Quick answer. PEP screening asks whether the person holds or held a prominent public function, or is a close associate, under the definition your policy uses. Entity screening asks who the legal entity is, whether sanctions lists name it or its owners, and what credible public reporting says. Adverse media is not an OFAC list. Beneficial ownership is not the registered agent.
Official office
Office of Foreign Assets Control
Steps
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Identify the legal entity
State, file number, status, date viewed.
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Screen names on OFAC
Entity and people, separately, with the search date.
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Read adverse media as news
Cite the original report. Ignore duplicate reposts.
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Ask for ownership documents
Do not invent members from the registered agent.
PEP screening looks for public roles
There is no official U.S. PEP registry. Record the role, the country, and the source. A former role may still matter under your policy for a period of time. The policy sets that period, not this website.
A PEP is not automatically sanctioned. Run the sanctions lists separately.
Separate the sources in the file
Pull the state file for the legal name, number, and status. Screen that name and the known owners in OFAC’s tool. Read adverse media as articles with dates, not as a second sanctions list. PEP screening looks for public roles under your policy.
Beneficial ownership comes from documents the company provides when the state file is silent. Federal BOI rules have changed. Read the current FinCEN page before you quote a filing duty. We do not submit that form.
Common mistakes
- Rating a company from headlines alone.
- Calling the agent the beneficial owner.
- Merging PEP and SDN labels.
- Quoting an outdated BOI deadline.
Questions
What is adverse media screening?
A review of credible reports about crime, fraud, or corruption. It is not an official sanctions list.
What is PEP screening?
A check for prominent public roles under your policy. It is not automatically a sanctions hit.
What is AML screening here?
The stack of sanctions, media or PEP checks you adopted, plus the legal-entity file. It is not a certificate of low risk.