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PEPs in practice: how do you draw the line?

At Vartion, we're conducting a short survey among AML, KYC, and CFT professionals to better understand how Politically Exposed Persons (PEPs) are managed across organisations.

PEPs could be considered high-risk, requiring enhanced due diligence and ongoing monitoring. While essential for mitigating financial crime, these measures can also lead to delays, inefficiencies, and even financial exclusion - not only for PEPs, but also for their families and associates. Outdated or overly rigid processes can miss real threats or create unnecessary barriers.

By sharing your experience, you help us learn how to prevent these issues - and contribute to making PEP risk management.

Does your organisation have a specific policy for dealing with PEPs?

Why we ask: Understanding how organisations define and apply PEP policies helps identify where clarity and proportionality can reduce unnecessary barriers to financial access.
Does your organisation have a specific policy for dealing with PEPs?
A
B
C
D
E

How is PEP risk assessed in your organisation? (Select all that apply)

Why we ask: Risk assessment practices vary widely; by learning how they’re applied in practice, we can better understand what contributes to fair and efficient outcomes.
How is PEP risk assessed in your organisation? (Select all that apply)

Which risk level is generally assigned to PEPs?

Why we ask: This helps us explore how risk ratings reflect real risk - and whether current approaches are aligned with proportional, risk-based compliance.
Which risk level is generally assigned to PEPs?
A
B
C
D
E

What Enhanced Due Diligence (EDD) measures are typically applied to PEPs? (Select all that apply)

Why we ask: EDD is essential, but if applied too broadly, it can lead to inefficiencies or exclusion. Your input helps identify where improvements in balance and focus may be needed.
What Enhanced Due Diligence (EDD) measures are typically applied to PEPs? (Select all that apply)

Does your organisation review and declassify PEPs and/or their close associates (RCAs) after they leave public office?

Why we ask: Ensuring PEP status doesn’t last longer than necessary is key to fair treatment. Understanding how declassification is handled helps us identify opportunities to support more appropriate timelines.
Does your organisation review and declassify PEPs and/or their close associates (RCAs) after they leave public office?
A
B
C
D

How clearly does your organisation communicate with PEPs regarding due diligence requirements?

Why we ask: Clear and respectful communication is essential for trust and transparency. Your response helps us understand how communication can be improved to support better client experiences.
How clearly does your organisation communicate with PEPs regarding due diligence requirements?
A
B
C
D

Which sector do you work in?

Why we ask: Each sector faces different regulatory and operational challenges.
Which sector do you work in?
A
B
C
D
E
F
G

What’s the biggest challenge your team faces in managing PEP cases? (Optional)

Why we ask: Your experience helps identify where the greatest pressure points lie—whether in risk clarity, data access, internal processes, or external expectations.

Can we contact you if we’d like to better understand your responses? (Optional - Email)