What PEP status means for a particular transaction

Choose the correct statutory branch

For general due diligence on a one-off transaction outside a relationship under Section 9(1)(a)(2), FAÚ guidance presupposes a Section 7 identification trigger: usually a value exceeding EUR 1,000 or an applicable trigger without a threshold. Do not equate this branch with separate Sections 9a and 15(2). A lower amount is not a universal exemption from every PEP measure; assess statutory grounds and conditions separately.

Section 9a(2)(c) requires enhanced identification and due diligence before a transaction or establishing a PEP relationship. Paragraph 4 sets minimum measures: additional wealth-origin information under paragraph 3(a)(3), enhanced monitoring under (c) and approval under (d). Distinguish a one-off transaction from a relationship rather than applying an identical workflow without that fact.

Approval under Section 9a comes from a statutory-body member or a person authorised by that member to manage the AML area. Record the decision-making role, approval scope and available evidence. A broker’s commercial agreement or automated checkbox does not replace required approval. Assess continuation when status is discovered in an existing relationship.

Distinguish funds from wealth origins

Funds origin explains the amount used in the transaction. Wealth origin explains the PEP’s financial position proportionately. A bank statement shows the sending account but may not explain the economic source. For a company purchase, business income, another share sale or financing may matter; connect explanations, evidence and amounts.

FAÚ guidance does not require an exhaustive inventory of every PEP’s and family’s assets in all cases. Evidence scope responds to risk, volume and transaction nature. Lower-risk circumstances do not remove mandatory measures. Unusual wealth or income discrepancies call for targeted explanations and evidence rather than an identical document package for everyone.

Monitoring and refusal are further decisions

Set enhanced monitoring of relevant changes and transactions. If required evidence cannot be obtained, assess Section 15; paragraph 2 specifically addresses a PEP transaction where the origin of the assets used is unknown. Assess suspicion separately and do not delay required reporting for internal approval rounds. Internal approval cannot override sanctions prohibitions.

Example of proportionate supplementation

When buying a ready-made company, a client says payment comes from selling another business share. Assess whether known circumstances, amount and timing make sense. Necessary supplements may explain the completed sale, proceeds and connection to the purchase funds. An inventory of every small family asset may be irrelevant. Evidence selection should resolve the actual question rather than merely expand attachments.

Before approval, identify substantiated facts, remaining uncertainties and measures addressing them. Authorised approval does not replace missing statutory information. After starting a relationship, reflect findings in monitoring, such as changed payment sources or owners. If the service lacks ordinary payment flows, adapt monitoring to its actual nature. A generic banking formula unrelated to the service does not ensure a usable measure.