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PEP Status — Not a Dead End: 4 Steps to Remove It
The Avagard Global team has a significant portfolio of successful cases on PEP status adjustments with a proven sequence of actions. We will tell you in which cases you can remove your PEP status and how to significantly increase your chances of being excluded from PEP lists.
PEP status carries serious risks for its holders: it increases the likelihood of international banks refusing to conduct any transactions, migration services — to obtain a residence permit, foreign companies — to cooperate, and also increases the risk of being included in sanctions lists.
However, PEP status is far from a death sentence. According to Avagard Global specialists, competent and effective work with a digital profile increases the likelihood of success in the event of removing PEP status by more than 1.5 times. Let's get started ... 4 steps to removing PEP status.
However, PEP status is far from a death sentence. According to Avagard Global specialists, competent and effective work with a digital profile increases the likelihood of success in the event of removing PEP status by more than 1.5 times. Let's get started ... 4 steps to removing PEP status.
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We will deactivate PEP status and help you overcome negative bank decisions.
STEP 1: Analysis of the person's dossier in databases
Banks, migration providers, compliance services of foreign companies use international risk assessment databases - Refinitiv World-Check, Dow Jones Risk & Compliance and Nexis Diligence (LexisNexis). They have a special section in each personal dossier on the person's connections with the state with links to sources confirming this.
Therefore, the first step in the process of removing the PEP status is to download the client's profile from the risk assessment systems. After that, Avagard Global specialists analyze the basis for the introduction and whether there is a chance to adjust the PEP status and offer the client an effective strategy.
Therefore, the first step in the process of removing the PEP status is to download the client's profile from the risk assessment systems. After that, Avagard Global specialists analyze the basis for the introduction and whether there is a chance to adjust the PEP status and offer the client an effective strategy.
The incorrect inclusion of a person in PEP lists is usually based on the lack of a generally accepted definition of the term PEP and the high level of trust of risk assessment systems in media publications and other open sources on the Internet, which may contain incorrect information
As for the definition of the term PEP, at the moment there is no single and generally accepted definition of PEP status. As a rule, this term refers to any person with ties to the state:
The lack of a generally accepted definition of PEP and vague wording in it, such as “business partners”, “government position” or “state companies”, allows for a rather free interpretation of this concept and the inclusion of a wide range of people in PEP lists, which creates room for error.
As for the definition of the term PEP, at the moment there is no single and generally accepted definition of PEP status. As a rule, this term refers to any person with ties to the state:
- officials and politicians in high government positions
- managers and members of the board of directors of state-owned companies
- close relatives of persons with PEP status, as well as their business partners
The lack of a generally accepted definition of PEP and vague wording in it, such as “business partners”, “government position” or “state companies”, allows for a rather free interpretation of this concept and the inclusion of a wide range of people in PEP lists, which creates room for error.
Avagard Global Case
Avagard Global had a case where PEP status was assigned to a former top manager of a state corporation. However, at the time when he held a management position there, the company was not yet state-owned, but was listed as a private enterprise. We managed to prove the fact of our client's non-involvement in state assets and remove his PEP status.
Avagard Global had a case where PEP status was assigned to a former top manager of a state corporation. However, at the time when he held a management position there, the company was not yet state-owned, but was listed as a private enterprise. We managed to prove the fact of our client's non-involvement in state assets and remove his PEP status.
Adjusting the PEP status is also complicated by the fact that, depending on the jurisdiction and the government position held, it can be assigned to a person from one to ten years or more after he or she left the position or ceased business ties with the state. After a person has left a PEP position or ceased cooperation with PEP or state-owned companies, it is important to at least change the status to Inactive PEP in order to completely remove the PEP status after some time.
The second most common reason for assigning the PEP status is the high trust of World-Check and other compliance systems in information on the Internet. In our practice, we periodically encounter cases where the PEP status is assigned based on outdated or unreliable information from Google and Yandex. This happens because risk assessment systems accumulate a large amount of data, not only from official sources, but also from publicly available sources - primarily what is issued on the first page of search engines.
The second most common reason for assigning the PEP status is the high trust of World-Check and other compliance systems in information on the Internet. In our practice, we periodically encounter cases where the PEP status is assigned based on outdated or unreliable information from Google and Yandex. This happens because risk assessment systems accumulate a large amount of data, not only from official sources, but also from publicly available sources - primarily what is issued on the first page of search engines.
Avagard Global Case
A client approached us with a request to remove his PEP status. During the analysis of his situation, it turned out that a series of articles had been published on the Internet, which indicated that he would take a management position in a planned company with state participation. But the company was never created, and the person ended up on the PEP lists due to this unreliable information in the media.
A client approached us with a request to remove his PEP status. During the analysis of his situation, it turned out that a series of articles had been published on the Internet, which indicated that he would take a management position in a planned company with state participation. But the company was never created, and the person ended up on the PEP lists due to this unreliable information in the media.
IMPORTANT: Any mention on the Internet of cooperation with government agencies and companies, as well as connections with specific PEPs, may be grounds for awarding PEP status, even if such mentions are false.
This is why the most important point in the strategy for removing PEP status is working with the client’s digital profile.
STEP 2: Analysis of a person’s digital profile
When analyzing a digital profile, it is important to consider not only information on the Internet about the sources of the PEP status — positions held and cooperation with state-owned companies, but also about other facts that increase the compliance risk for a person — publications in open sources about legal proceedings, sanctions connections, corruption cases or other situations involving a person that damage business reputation.
When sending a request to remove the PEP status to the risk assessment system, the information is updated and a new check of the entire client profile is launched. If “red flags” are detected during such a check, this will be added to the system, which will worsen the situation with the person’s risk profile, while the PEP status itself may be removed.
When sending a request to remove the PEP status to the risk assessment system, the information is updated and a new check of the entire client profile is launched. If “red flags” are detected during such a check, this will be added to the system, which will worsen the situation with the person’s risk profile, while the PEP status itself may be removed.
IMPORTANT: Compliance officers do not look at all mentions of a person on the Internet, but often limit themselves to the first page of results for search queries that include the person’s first and last name.
There is simply no time for a deeper search, and usually there is no need - after all, as a rule, the first page contains the most up-to-date and complete information about a person.
IMPORTANT: Upon receipt of an application, World-Check analysts will check not only Google results in English in the UK, but also in the applicant's native language, i.e. Yandex and Google in Russian in the case of checking a person with Russian citizenship.
Avagard Global Case
In Avagard's Global practice, we have repeatedly encountered situations where a person has not held a government position for a long time, but there are still many articles on the Internet where he is called a politician. If this state of affairs is left, international databases may ask additional questions, which can significantly delay the process of removing the PEP status, and in the worst case, refuse to remove the PEP status without additional explanations.
In Avagard's Global practice, we have repeatedly encountered situations where a person has not held a government position for a long time, but there are still many articles on the Internet where he is called a politician. If this state of affairs is left, international databases may ask additional questions, which can significantly delay the process of removing the PEP status, and in the worst case, refuse to remove the PEP status without additional explanations.
Even if a person has all the legal evidence of their non-involvement in government structures, risk assessment systems will definitely check this information on the Internet. Submitting an application with a convincing package of documents is often not enough to remove the PEP status.
Trust in publicly available resources on the part of risk assessment systems is due to the fact that compliance officers and analysts of World-Check most often cannot fully assess the reliability of legal documents of each individual country and recheck the information in open sources.
It is important to take into account that Russian citizenship or ties to the Russian Federation are an aggravating circumstance for those who want to remove the PEP status. In itself, it will prevent a person from entering the risk zone. Compliance systems will check such a person especially carefully when requesting an adjustment of the PEP status. World-Check is likely to refuse to remove the PEP status in order to avoid taking on additional risks, so it is critical for such individuals to optimize their digital profile before applying for a PEP status adjustment.
Trust in publicly available resources on the part of risk assessment systems is due to the fact that compliance officers and analysts of World-Check most often cannot fully assess the reliability of legal documents of each individual country and recheck the information in open sources.
It is important to take into account that Russian citizenship or ties to the Russian Federation are an aggravating circumstance for those who want to remove the PEP status. In itself, it will prevent a person from entering the risk zone. Compliance systems will check such a person especially carefully when requesting an adjustment of the PEP status. World-Check is likely to refuse to remove the PEP status in order to avoid taking on additional risks, so it is critical for such individuals to optimize their digital profile before applying for a PEP status adjustment.
STEP 3: Optimisation of a person’s digital profile
After identifying the entire volume of outdated and incorrect information about the client on the Internet, it is necessary to neutralize it and create a new necessary digital profile of the person that would reflect his current status. Information about the person's new status should be posted in authoritative and cited media and contain information about the absence of connections with the state, for example, his business activities or a new managerial position in a private company.
It is important not only to publish this information, but to promote articles with it in such a way that they dominate the information field, namely, occupy the first lines of search results for queries containing the person's full name.
The goal of such promotion is that the entire first page of search results (literally 10 links out of 10) for a query with the client's last name and first name contain only articles about his new status, displacing outdated publications about his connection with politics. Moreover, it is necessary to work in Yandex and Google, both in Russia and abroad (in the case of working with the World-Check database, media in the UK are considered).
It is important not only to publish this information, but to promote articles with it in such a way that they dominate the information field, namely, occupy the first lines of search results for queries containing the person's full name.
The goal of such promotion is that the entire first page of search results (literally 10 links out of 10) for a query with the client's last name and first name contain only articles about his new status, displacing outdated publications about his connection with politics. Moreover, it is necessary to work in Yandex and Google, both in Russia and abroad (in the case of working with the World-Check database, media in the UK are considered).
IMPORTANT: Avagard Global specialists’ experience shows that comprehensive work with a client’s digital profile, including neutralizing false information and posting relevant information, increases the chances of removing PEP status by more than 1.5 times.
Avagard Global uses all available and effective tools to work with unreliable publications, in particular:
- displacing from the first pages of search results
- deindexing (removing data from search by the "right to be forgotten")
- negotiations with the site administration and removal through them ("removing")
- removal through the court
STEP 4: Submitting official documents
The documents submitted to the international risk assessment databases for removing the PEP status based on the results of the work done depend on the specific case and its input. As a rule, an official request is sent to the risk assessment systems, a legal opinion finalizing the general position on the basis of which the person requests to remove the PEP status, and documents confirming the resignation from the government position and the current status not related to the government and PEP (on entrepreneurial activity, for example).
If comprehensive work was previously carried out with the digital profile of the person on the Internet, then the probability of removing the PEP status is high. If this block of work was ignored or done poorly, a significant delay in the process or a refusal to adjust the PEP status is possible.
If comprehensive work was previously carried out with the digital profile of the person on the Internet, then the probability of removing the PEP status is high. If this block of work was ignored or done poorly, a significant delay in the process or a refusal to adjust the PEP status is possible.