Fact Sheet: PEP-Check
Compliance & Risk Solutions - Automatic check on money laundering and risks
The increasing demands for regulatory compliance have resulted in financial institutions needing to diligently follow anti-money laundering and know your customer (KYC) onboarding regimes in order to manage risks of investments and transactions using illegally procured funds.
PEP-Check enables organizations to run checks on potential and existing clients against official sanction lists, PEP (politically exposed person) lists, and risk lists (watch lists and blacklists) as required by law and recommended by the international FATF (Financial Action Task Force).
Assurance of knowing lists are obtained from official government offices and compliance specialists.
Save on time and efforts with saved user configurations and automatic list updates taking place every time PEP-Check is launched.
Provide management and regulators with timely, detailed reports in a variety of audit-standard formats as proof of due diligence.
Easy integration into a wide range of checking processes and systems for an efficient workflow.
- Individual name check.
- Batch checks (customer lists).
- Transaction check.
- Hit verification module.
- Auto adjusting White List.
- Periodical risk screening of customer base
- Add private lists or content from 3rd party providers
- Advanced search options for in-depth investigations.
- Multi-client capability allows for the best configurations to suit each checking process.
The flexibility of PEP-Check ensures it is the right solution for every due diligence checking process whether it be running routine customer screenings, transaction checks, or kick-starting in-depth investigations.
PEP check can be operated in ASP-mode as well as a client installation in your company's secure IT landscape.
Questions? We have answers.Get in touch and we'll connect you to the right representative.
This privacy statement explains how SIX Financial Information Ltd (“SIX” “we”, “us” or “our”) collects, processes, handles, discloses, stores and protects information about you in the context of our PEP Check service (“PEP Check”).
1. What this privacy statement covers:
This privacy statement only covers PEP Check. Alternative privacy statements may apply to other products, services and websites made available by SIX or our holding companies, subsidiaries or affiliated companies (together the “SIX Group”).
2. Who PEP Check holds information about
- PEP Check holds information that helps financial institutions, corporates, professional services firms, governments, law enforcement agencies, regulators and others (“SIX Customers”) to perform due diligence and other screening activities in accordance with their legal or regulatory obligations and risk management procedures carried out in the public interest (“Checks”).
- PEP Check is designed and maintained to improve the speed, accuracy and transparency of Checks which are carried out on customers and counterparties, related to anti-money laundering (AML), countering terrorist financing and other unlawful acts, ‘know your customer’ (KYC), and anti-bribery and corruption requirements.
- PEP Check is not aimed at children. In the limited circumstances where we collect and use personal information about children (for example, because they are the children of a PEP (as defined below)), we comply with industry guidelines and applicable laws.
- Personal information is only included on PEP Check if Public Domain Data (as defined below) suggests that there is information about the relevant person that SIX Customers need to be aware when conducting such Checks.
The inclusion of information (e.g. personal data) about you on PEP Check does not prevent you from doing business with SIX Customers such as financial institutions. You can find out if information about you is on PEP Check here (please mention PEP-Check in the request).
Your information may be included on PEP Check if Public Domain Data indicates that:
- you are a “politically exposed person” (“PEP”) as defined by the FATF Recommendations or fall into a similar category of persons (for example, you are a senior diplomat, member of the judiciary, religious leader, military figure or trade unionist) under national laws or regulations against money-laundering, terrorist financing, bribery or corruption.
- you are a close associate of a PEP, as defined in the FATF Recommendations. Close associates may include children (for example, the children of a PEP and other minor dependents of a PEP). Where we do collect information about children we will comply with applicable laws and industry guidelines.
- you are listed on the website of a regulator, law enforcement authority or governmental body in connection with money-laundering, bribery, corruption, terrorist financing or similar activities;
- you are included on a government or international body’s sanctions list (e.g. sanctions lists issued by the European Union, United States, United Kingdom, Switzerland and others);
- you are linked to financial crime-related or terror-related activities;
- you have been investigated, arrested, charged, accused or convicted of crimes which are a possible predecessor to terrorist financing (e.g. arms trafficking, smuggling, fraud, war crimes etc.) and/or money laundering, or you are suspected to be involved in these activities; or
- you have been convicted, investigated, charged, arrested, or accused of statutory or regulatory offences;
- you are prohibited or have been disqualified from holding positions of responsibility (such as company directorships).
If there is any information about you in PEP Check this does not suggest that you are involved in, or linked to, financial crime, terrorism or any other criminality or unlawful act. For example, being identified as a PEP simply tells a SIX Customer that you have or once have had a prominent political or related function or are connected to someone that holds or held such a position.
SIX Customers decide about how to use the PEP Check data they receive in order to conduct their checks. Therefore, if you wonder about these decisions, please refer them to the relevant SIX Customer.
“Public Domain Data” means, for the purpose of this privacy statement, personal information originally available to the public, from various official sanctions lists (SECO, OFAC, UN, etc.), Politically Exposed Persons from 240 countries’ ministries, and 1400 blacklists (e.g. FBI’s most wanted). The feed is restricted to government-issued information, and excludes any other sources such as media, controversies, rumors, social networks, etc.
3. What kind of personal data do we process
The following types of information about you may be held in PEP Check:
- Inclusion (if any) on sanctions lists or on public lists of disqualified directors or other positions of responsibility.
- Public Domain Data about actual or alleged money laundering or terrorist financing crime, or crimes that are a predecessor to terrorist financing or money laundering which are also known as predicate offences (e.g. financial crime, illegal trafficking, environmental offences, Professional and personal affiliations (e.g. organizations (including sanctioned vessels and aircraft) and individuals that may be associated with in the professional or personal capacity).
- Information that helps to identify you (e.g. name/s; alias; date of birth; gender; country of residence; passport details; citizenship).
- Personal identification numbers (e.g. national insurance numbers, social security numbers) that are Public Domain Data.
- Family status and/or circumstances (e.g. your marital status and dependents) if you are a PEP or a close associate of a PEP.
In certain cases, personal information on PEP Check includes so-called ‘sensitive’ or ‘special categories’ of personal information such as: political opinions (e.g. PEP); sexual orientation (e.g. spouse or partner of a PEP); religious beliefs (e.g. religious leader that qualifies as a PEP); racial or ethnic origin; trade union membership; criminal offences actually or allegedly committed (e.g. money-laundering, terrorist financing offences or predecessor crimes to such offences).
Our supplier Info4C has robust controls so that the personal data used in PEP Check is accurate, relevant and not excessive. Together, we comply with detailed research and screening processes for sourcing PEP Check information and we monitor compliance with these processes.
4. How we use information about you
Information on PEP Check is processed (e.g. collected, used, shared and retained) for the purposes of:
- exercising our rights, and to defend ourselves from claims and to comply with laws and regulations that apply to the SIX Group or third parties with whom we work;
- supporting the operation of PEP Check.
5. What legal grounds do we use to process your information
SIX is required to set out in this privacy statement the legal grounds on which SIX relies in order to process personal information.
Personal information is processed on the basis that it is in PEP Check Customers’ legitimate interests to carry out checks to ensure that they can comply with their legal and regulatory obligations and protect the public from fraud, financial crime and serious misconduct or dishonesty. It is in SIX’ legitimate interests to carry on a business to facilitate those Checks. SIX and the public have a legitimate interest to ensure that fraud, financial crime and serious misconduct or dishonesty are prevented and detected which is why it is reasonable for you to expect that your information may be used for the carrying out of checks in the public interest. It is possible that your interests differ from SIX’ and SIX Customers’ interests, as inclusion of personal information on PEP Check results in further checks being carried out by SIX Customers prior to a decision being made about whether to enter into an arrangement or not. The legitimate interests in carrying out checks would however not be overridden by your interests, given the significant public interest in the carrying out of these checks.
SIX processes your special category information on the basis that:
- in all other cases, the processing is required for reasons of substantial public interest, on the basis of applicable law (including laws designed to combat money-laundering, bribery, corruption and avoidance of sanctions).
SIX processes information about actual or alleged criminal offences on the basis that it is authorized by applicable law.
6. Who we disclose your personal information to:
If there is information about you on PEP Check, it is therefore only made available to the above-mentioned parties.
7. How we secure your personal information
These policies and measures include:
- controls around the inclusion and maintenance of PEP Check information that are designed to ensure that personal information on PEP Check is accurate and relevant;
- education and training of employees to ensure that they are aware of and comply with our policies, procedures and controls designed to keep PEP Check information secure, accurate and relevant;
- monitoring compliance with our policies, procedures and controls.
- physical security measures, such as security passes and controls on access to locations of PEP Check servers;
We also impose contractual restrictions on SIX Customers and business partners requiring them to only use information on PEP Check in connection with checks.
8. Why information may be transferred abroad
9. How long we keep personal information
10. Your rights
Persons whose Personal Data is processed within the scope of this Privacy Statement have the following rights:
- to receive a copy of the Personal Data
- to request the rectification of Personal Data if it is incorrect
- to request the deletion of Personal Data
- to request restrictions on processing Personal Data
- to receive Personal Data in a structured, accessible and machine-readable format
- to submit an objection to processing, especially for the purpose of direct advertising
The rights specified above may be denied or restricted if the interests, rights and freedoms of third parties take precedence or if processing is necessary to establish, exercise or defend legal claims of SIX.
Queries in relation to processing Personal Data are to be directed to the Data Protection Officers of SIX: