PEPs & Sanctions Results | Unity Onboarding

This article walks you through results available via the Unity Onboarding + KYC, if you are looking for help for the Unity Client ID Verification product, please view the resources here. If you are looking for help for the Unity PMS product, please view the resources here. 

PEPs & Sanctions Results

This article discusses the PEPs & Sanctions results you may see within Unity Onboarding. The article is split into four sections: 

1) Overall Result; 

2) PEPs & Sanctions Criteria; 

3) Pass Result;

4) Refer Result.

Section 1: Overall Results

For PEPs & Sanctions checks you will be presented with one of two overall results:

If the overall result appears as 'Pending', you will be presented with all the possible matches to your client. For these cases you will need to investigate and remediate the results and confirm if the possible matches are your client.

If available, we will provide the following information for you to help you decide if the possible matches are your client:

    - An image of the individual who has appeared as a possible match

    - The possible matches full name

    - The possible matches date of birth

    - The possible matches nationality

    - The possible matches gender

You will then be presented with a table outlining the reason for the flag. The different checks that may cause a flag are covered in the next section below.

Section 2: PEPs & Sanctions Criteria

Possible matches will flag if the following conditions are met:

    - The possible match has a recorded date of birth that matches that of your clients OR the possible     match does not have an associated date of birth.

    - The possible match has a recorded name which is the same as the name you have provided for          your client.

    - The possible match has been flagged for at least one of the below areas.

Our PEP's & Sanctions checks encompasses five different areas, all of which cover UK and international individuals:

International PEP's: The individuals name and date of birth will be checked against International & Domestic PEP databases. Current, previous and associated PEP's from PEP tiers 1-3 will be flagged.

International Sanctions: The individuals name and date of birth will be checked against International & Domestic sanction databases. Current, previous and associated sanctions will be flagged.

Adverse Media: Evidence that the individual has been reported & involved in financial crime from global newspapers, news sites or other verified media will be flagged.

Disqualified Director: Evidence that the individual has been disqualified as acting as a director of a UK company, sourced directly from Companies House, will be flagged.

Law Enforcement: Evidence of official documentation from Law Enforcement bodies such as the Police or any other agencies such as Interpol or the FBI will be flagged. 

Please see the PEPs & Sanctions guide at the bottom of this article that describes what each PEP & Sanctions check looks at in more details and the sources of information.

Section 3: Pass Result

If the PEPs & Sanctions has passed, no matches will be presented in the PEPs & Sanctions tab as below.

Section 4: Refer Results

If the PEPs & Sanctions check comes back as pending, you will need to investigate these results and confirm if any of the possible matches flagged are your client, and if so, complete a risk assessment on the individual. If you are unsure on the next steps, we recommend speaking to your compliance officer/MLRO for clarity.

When the results come back as pending, you will be presented with a full list of possible matches. To find out more information on each of the possible matches, click the 'view full report' associated with the individual. In the below example, I can see that the individual has flagged as a PEP, therefore I would go into the PEPs tab as part of the full report to find out more information about them.

To remediate the results, you will then need to either match (fail) or mismatch (pass) the results to your client, you can do this in two ways:

1. You can review each possible match individually by clicking 'Validate'.

2. You can review the possible matches as a whole. Click the 'Review now' button at the bottom of the corner of the screen. When matching/mismatching the check you will always have to write a comment, this is so there is a record of the change of status. If you are unsure what to write in the comment section, please speak to your manager. This note will appear within the portal and also on the PDF.

You also need to tick the 'I confirm that this data is correct' to continue.

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