PEP assessment record

For: Client due diligence staff

PEP status is neither an accusation nor an automatic relationship ban.

Before use

Check current sector rules in the related articles. Add accountable roles, specific sources and steps actually performed. Do not enter unnecessary personal data.

How to complete the template

1. Relevant person and relationship to the client

   Is this the client, representative, owner or a person connected to a PEP? Record the role and identifiers needed to distinguish them.

2. Public function or relevant personal/business connection

   Which public function was held and in which country? For connected persons describe the family or relevant business relationship.

3. Declaration, other proportionate sources, date

   Separate client statements from findings; record URLs or document references, dates and unresolved conflicts.

4. Current or former function and continuing risks

   When did the function end? Assess a former PEP for at least twelve months and longer while risk persists; leaving office does not automatically end measures.

5. Conclusion, source of funds/wealth, approval and review

   Record enhanced measures, source of funds and wealth review, required approval and ongoing monitoring under sections 9a and 15.

Illustrative use

MODEL PEP-01: client reports leaving a prominent public function six months ago. Record: function and end evidenced. Conclusion: departure alone does not end measures; document enhanced measures and approval.

When the case is uncertain

Result “unsure”? Request specific evidence. If a PEP is established, use appropriate enhanced measures rather than automatic rejection.

Legal basis: § 4 odst. 5, § 9a, § 15, § 54 odst. 8

V05-2026-10-04 · Redakce eAML.cz

Related guidance