Step 1
Send the customer's details
The surname and first name are required. A patronymic, date of birth, country and sex cut down the number of namesakes. The data can go through the API or come from a document read in a KYC session.
PEP screening: checking politically exposed persons
Screening politically exposed persons and their circle in a single API request. For every match — the similarity score, whether the person is a current, former or linked PEP, and which other databases they appear in: sanctions, regulatory measures, adverse coverage.
Full name Date of birth Country Sex KYC session
Whom PEP screening looks for: categories of politically exposed persons
A PEP (politically exposed person) is someone entrusted, now or in the past, with prominent public functions. Russian law calls them public officials. Article 7.3 of 115‑FZ sets out three categories, and the requirements differ: screening must not only find the person but show which of the three they are.
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Foreign politically exposed persons
- Heads of state and government, senior politicians, senior officials, judges and military officers, heads of state corporations in other countries
- 115‑FZ, art. 7.3, cl. 1, item 1 and cl. 4: status is determined by the FATF recommendations
- The measures always apply, with no risk-level condition
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Officials of public international organisations
- Directors, deputy directors, board members or equivalent posts
- Art. 7.3, cl. 1, item 1 and cl. 4
- The measures apply if the client has been assigned a high risk level
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Russian politically exposed persons
- State offices of the Russian Federation, members of the Bank of Russia Board of Directors, federal civil service posts filled by the President or the Government, and posts at the Bank of Russia, state corporations and organisations set up by federal law
- Art. 7.3, cl. 1, item 1 and cl. 3; the consolidated list of state offices — Presidential Decree No. 974 of 14.11.2024
- The measures apply if the client has been assigned a high risk level
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Spouses and close relatives
- Parents and children, grandparents and grandchildren, full and half siblings, adoptive parents and adopted children
- Art. 7.3, cl. 1, item 5 — for foreign PEPs; for the other two categories — through cl. 3, at a high risk level
- Enhanced attention to transactions. The service returns the status «linked PEP»
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Former officials
- Those who have left office: under the FATF definition the functions are «entrusted or have been entrusted»
- Neither the law nor FATF sets an automatic time limit
- The answer carries the status «former PEP»; how long to take it into account is for the internal control rules
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Close associates (FATF)
- The FATF standard's notion of close associates; 115‑FZ has no such concept
- If the database shows a person as linked to a PEP, that is a risk signal, not a statutory duty
- The categories, relatives and difficult cases in detail — in an article on politically exposed persons
What 115‑FZ requires when a client is a politically exposed person
The law requires not merely finding a PEP but applying the measures for their category. Screening covers the first step — finding them. The rest is for your compliance team under its internal control rules.
- Take reasonable and available steps to identify them
- Take them on only by written decision of the head of the organisation or their deputy
- Establish the source of their funds and property
- Update the client's details regularly
- Pay enhanced attention to the transactions of the client, their spouse and close relatives
- Identify them among your clients — always
- The same measures as for foreign PEPs — if the client has been assigned a high risk level
- Officials of international organisations are determined by the FATF recommendations
- Russian offices — by the lists the President determines
- Banks do not apply the requirements to cash currency exchange up to 40,000 ₽ or to transfers without an account up to 15,000 ₽ — unless the transaction raises suspicion
- Advocates, notaries, auditors and providers of legal and accounting services — identification, source of funds, updating the details, attention to transactions
- Client details are updated at least once a year, at low risk — once every three years, and where there is doubt — within seven working days
- Based on 115‑FZ as in force on 04.08.2026. How the requirements apply in your organisation is set by its internal control rules.
Who needs a PEP check
Every organisation carrying out transactions with money or other property under 115‑FZ must identify politically exposed persons, and in the cases listed in article 7.1 so must lawyers, notaries and auditors. What differs is the volume and where the check sits.
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Banks and payment services
Screening when an account or wallet is opened, and when the client file is updated. A match goes for manual review before the decision to take the client on.
Solutions for the industryMost often enabled:
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Brokers and asset managers
Clients with foreign citizenship and large assets are checked before their first order, together with the source of funds.
Solutions for the industryMost often enabled:
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Microfinance companies, pawnshops, credit cooperatives
The check sits in onboarding next to the passport and the Rosfinmonitoring watchlist — with no separate service.
Solutions for the industryMost often enabled:
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Insurance and leasing companies
Policyholders, beneficiaries and lessees are checked when the contract is signed.
Most often enabled:
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Estate agents and precious metals dealers
A large deal with a buyer seen for the first time: PEP status is checked before the money moves.
Most often enabled:
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Advocates, notaries, auditors
In the cases listed in article 7.1 of 115‑FZ — a check on the principal, with no annual subscription, at the price of a single check.
Solutions for the industryMost often enabled:
How a client's PEP screening works
There is no single official list of politically exposed persons anywhere in the world. So the service matches the client against a consolidated database of PEP profiles and their circle, and shows how closely the record found resembles your client.
Step 2
The service looks for similar profiles
The name is compared with profiles of PEPs, linked persons, sanctions lists, regulatory measures and adverse coverage. A match counts if the similarity is no lower than 95 out of 100.
Step 3
You get the matches with their details
For every profile — the similarity score, the PEP status (current, former, linked), the database categories, the countries and the dates of birth in the record. The decision on the client is your compliance team's.
How the service finds a PEP among similar names
Between an exact match and «by surname»
An exact match misses a PEP spelled differently; a search by surname buries you in namesakes
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Fuzzy matching instead of exact
The service compares strings for similarity and scores each profile from 0 to 100. Profiles scoring 95 and above come back, and the highest score goes in the field
maxScore. That is how it finds records with a missing patronymic, a swapped first name and surname, a typo or a hyphen in a double-barrelled surname. - 02
Transliteration and different spellings
Foreign PEP profiles are kept in Latin script, and one Russian surname produces several spellings: Streltsov, Strel'cov, Streltzov. The field
matchedNameshows the spelling the record matched on. For Russian citizens it is safer to send the name as it appears in the international passport. - 03
Date of birth, country and sex filter out namesakes
The date of birth is compared to the year, and the country and sex against the profile data. If the profile has no date of birth or country, the service does not drop it: better one record too many than a real one missed. Matches like that are reviewed by a person.
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Status and categories in a single record
One profile can be a PEP, sanctioned and named in adverse coverage all at once. Every record carries a list of categories and three PEP flags: current (in office now), former (in office before) and linked (a relative or close associate).
- 95 the similarity threshold out of 100
- to the year how precisely the date of birth is compared
- 4 categories: PEP, sanctions, regulators, media
A current PEP, a linked person or a namesake
False positives: how to review a match
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A confirmed PEP or linked person
Similarity 95+, the year of birth and country agree, status «current PEP» — check the office held against open sources and the client file, then apply the measures for the category. Status «linked PEP» — check the family tie in the client file: enhanced attention if confirmed.
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Namesake
Similarity 95+, but the year of birth does not match the client's document — this is a namesake, and the check is passed. Record the decision and its grounds together with the result.
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Manual review
The profile has no year and no country — check the sex, the patronymic and the client file, and ask the client if in doubt. «Former PEP» — a decision under the internal control rules. The categories
pepandsanctionstogether — review it as a sanctions match.
Most matches are namesakes: the threshold is set so as not to miss real public figures. The order of review: matchScore and matchedName → year of birth → country → categories → a question to the client → a decision with grounds. Screening does not replace asking about PEP status in the client questionnaire — it complements it. More — in an article on false positives, and sanctions matches — on the sanctions screening page.
The PEP screening API response: fields and an example
PEP screening is the check complianceScreening in the AML API: run it on its own or together with other checks, and the result comes back by run identifier or by webhook. Send the surname and first name — required; the patronymic, date of birth (compared to the year), country and sex — to filter out namesakes. The parameter names are in the API documentation.
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passed—true: no matches;false: profiles found, review needed -
matchScore— how closely the name matches the profile, 0–100 -
matchedName— the spelling the record matched on -
categories— where the person was found:pep,sanctions,adverse_media,regulatory
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isPepCurrent/isPepFormer/isPepLinked— current, former or linked PEP -
pepTier— PEP tier under the provider's classification -
isActiveSanction/isFormerSanction— active or lifted sanctions -
details.threshold— the threshold from which a match appears in the response -
details.isTruncated— the list of matches is truncated: narrow the query by date of birth or country
- The value from the sample response is in the pill next to each field. The data in the sample is fictitious; check fields and codes against the API documentation.
When to repeat a PEP check
PEP status changes: a person is appointed to office, leaves it, or a relative becomes a public figure. A check at onboarding shows the position on a single day, which is why it is repeated.
- API documentation
By law
115‑FZ, art. 7.3, cl. 1, items 1 and 4; art. 7, cl. 1, item 3.
Taking the client on
- Screening before the decision to accept; for a foreign PEP — before the written decision of the head of the organisation
The scheduled update of the details
- At least once a year, and for low-risk clients — once every three years
Doubts about accuracy
- Update the details within seven working days
The client is a foreign PEP
- Update the details «on a regular basis»: the law sets no interval — the internal control rules do
- Counterparty checks
Under the internal control rules
When the client or their transactions change.
The details have changed
- The name, citizenship or document — repeat the screening with the new data
New people
- A new representative, beneficiary or beneficial owner — check them in the same request. A company's beneficial owners and representatives are easier to check together with the company itself
Transactions
- An unusual or large transaction — repeat the check before it goes through
- Connect the PEP check
What a repeat costs
The same as the first check, with no subscription fee.
Price
- 36 ₽ for a repeat check
In batches
- A list of clients for batch checking can be sent through the API
What PEP screening costs
A fixed price per check, with no subscription fee. Checks skipped for lack of data are not charged for.
- Enable
Watchlist and sanctions
5 ₽ per check
The Rosfinmonitoring watchlist, or the OFAC, EU, UK and UN sanctions lists — as separate checks.
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Politically exposed persons and their circle, sanctions from 50+ countries, regulatory measures and adverse media in one request.
- Enable the package
The «16 in 1» basic package
50 ₽ per package
Sixteen checks from a single passport, the Rosfinmonitoring watchlist and international sanctions among them. PEP screening is added to the package as a separate check.
Connecting PEP screening: API, KYC session, web portal
PEP screening is the method complianceScreening in the AML API. Run it on its own or together with the Rosfinmonitoring watchlist, sanctions and checks against Russian registers.
- The similarity score
- PEP status
- Database categories
- JSON in and out
Test access on the day you ask for it.
Integration takes from one working day. NeuroVision engineers support you throughout the roll-out.
Read also
Politically exposed persons, false positives and the risk-based approach — in our blog.
139 30
KYC, AML and Digital Identification
Politically Exposed Person (PEP): Who It Is and What 115-FZ Requires
393 23
KYC, AML and Digital Identification
How Sanctions Screening, PEP Checks, and Risk Profiling Work After Customer Identification
339 28
KYC, AML and Digital Identification
Risk-based KYC: how to choose the verification level by risk profile
408 10
KYC, AML and Digital Identification
False Positives in AML Screening: How to Reduce Escalations and Preserve Onboarding Conversion
Common questions about PEP checks
PEP categories, namesakes, relatives and whether the check is mandatory — the essentials in brief.
It is a check on whether a client belongs to the politically exposed persons (PEP) or their circle. The service compares the client's name and other data against a database of profiles and returns similar records with a similarity score and a status.
Current and former politically exposed persons and the people linked to them — relatives and close associates. The same request also checks sanctions lists from over 50 countries, regulatory measures and adverse coverage.
Yes. Organisations carrying out transactions with money or other property must take reasonable and available steps to identify politically exposed persons (115‑FZ, art. 7.3, cl. 1, item 1). In the cases listed in article 7.1 this also covers advocates, notaries and auditors. Screening is a tool for that check. Which further measures to apply is for the organisation to decide under its internal control rules.
The questionnaire and the screening complement each other. A client may not know their post is on the list, or may not declare a family tie. A database may not know about a recent appointment. FATF says plainly that a commercial database is neither required nor sufficient on its own — so using both sources is safer.
By the similarity score and the profile data: the year of birth, the country and the sex. The more data you send, the fewer namesakes reach the response. Matches whose profile has no date of birth are reviewed by hand.
Yes, where the person is in the database as a linked person — the response will carry the status «linked PEP». The law requires enhanced attention to the transactions of the spouses and close relatives of foreign PEPs, and for the other two categories — at a high risk level.
Neither 115‑FZ nor FATF sets an automatic period. The service marks such a person as a former PEP, and how long to take the status into account is for the internal control rules and the risk assessment. More — in an article on politically exposed persons.
Being a politically exposed person is grounds for additional measures, not for refusal. Rosfinmonitoring's guidance does not allow refusal on that ground alone. The status does not override the other grounds for refusal that the law provides.
PEP is a characteristic of an office: the person has broken no law, but additional measures apply to them. Sanctions status is a decision by a particular country's authority. At NeuroVision both checks run in a single request: PEP screening already covers sanctions from over 50 countries, and the four main lists — OFAC, the EU, the UK and the UN — are in sanctions screening for 5 ₽.
Yes, the service accepts names in Russian. For Russian citizens with an international passport it is more accurate to send the name in Latin script exactly as in the document: that is how foreign sources record it.
When the client is taken on and at every update of the details: at least once a year, and once every three years for low-risk clients. The law requires details on foreign PEPs to be updated regularly, with the interval set by the internal control rules.
36 ₽ per check, with no subscription fee. The price covers PEP lists, sanctions lists from over 50 countries, regulatory measures and adverse media. Checks skipped for lack of data are not charged for.
Connect the PEP check
Tell us which clients you check and in what volume — we will give you test access and a sample response on your own data.
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