PEP Screening for Latin American Compliance Teams

Identify politically exposed persons, their family members and close associates, and keep the evidence of every check in the client file.

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Knowing that a client holds or held a prominent public function does not close a relationship: it raises the level of due diligence. COX records who is a PEP and why, screens the client and the people around them, and flags when the file needs enhanced due diligence. The decision stays with your compliance officer.

Who Counts as a PEP

The common reference is the guidance of the Financial Action Task Force (FATF) on Recommendations 12 and 22. It describes three kinds of politically exposed person, and extends the treatment to the people close to them:

Foreign PEPs: people entrusted with a prominent public function by another country.
Domestic PEPs: people entrusted with a prominent public function by the country itself.
PEPs of international organizations: members of senior management of an international organization.
Family members and close associates: relatives by blood, marriage or civil partnership, and people with close social or professional ties to the PEP.

Which positions qualify, how far the family goes and how long the status lasts are set by each country. Middle-ranking and junior officials are not PEPs.

What COX Does With a PEP

The same file carries the status, the screening, the risk and the decision.

PEP status in every file

Each client file records whether the person is a PEP, national or international, related to one, or neither, with the position, the institution, the country and the dates of office.

Family members and associates

Linked persons carry their own PEP status. For a legal entity, the beneficial owners, directors and representatives are recorded and screened as well.

Screening against PEP lists

The same search checks PEP lists, such as the register that Colombia's Función Pública publishes, together with sanctions and restrictive lists, and reports which lists were searched and as of which date.

Risk matrix and enhanced due diligence

Your risk matrix weighs PEP exposure, direct or through beneficial owners, and flags when the file requires enhanced due diligence. The file cannot be approved until it is documented.

Monitoring after onboarding

Continuous monitoring checks your files against each new edition of the lists and opens an alert for a person to review.

Evidence for your supervisor

Every match is confirmed or dismissed by a person, with a reason, and the report states what was searched and how.

The Rule Changes From Country to Country

Some examples from the countries COX serves. They summarize the rule without replacing it.

Panama

Law 23 of 2015 treats a person as a PEP from the appointment until they leave office, and for a later period of no more than two years. The SSNF issued its comprehensive guide on PEP positions, close associates and close family members in Resolution S-008-2026.

PEP screening in Panama

Mexico

Since the reform of the LFPIORPI Regulation published on 27 March 2026, the Financial Intelligence Unit (UIF) keeps a List of Politically Exposed Persons, and obligated parties that cannot determine whether a client is a PEP may consult the UIF.

COX in Mexico

Dominican Republic

Law 155-17 keeps the PEP status while in office and for three years after leaving it, and extends it to spouses, relatives up to the second degree and close associates.

COX in the Dominican Republic

Colombia

Función Pública publishes the register of politically exposed persons, and COX searches it together with the other national and international lists.

COX in Colombia

In Guatemala and Venezuela, COX applies the same controls, and the enhanced due diligence is the one your risk matrix and your supervisor's rules require: Guatemala · Venezuela.

Frequently Asked Questions

No. The FATF guidance says the PEP requirements are preventive, and that refusing a client only for being a PEP goes against Recommendation 12. What changes is the depth of the due diligence: source of wealth and funds, approval by senior management where the rule requires it, and closer monitoring.

It depends on the country. The FATF guidance recommends a risk-based approach rather than a fixed term; Panama sets a later period of no more than two years and the Dominican Republic, three years. COX records when the person took and left office, and your compliance officer decides when the PEP treatment ends: the platform does not end it on its own.

Yes. Family members and associates are recorded in the client file as linked persons, each with their own PEP status, and can be screened like the client. For a legal entity, the same applies to its beneficial owners, directors and representatives.

The match is shown for review. A person confirms or dismisses it, with a reason, and the file cannot be approved while a match is pending. A confirmed PEP match feeds the risk matrix.

No. A sanctions list designates people you must not deal with; a PEP list tells you who needs enhanced due diligence. COX keeps them apart, and the risk matrix scores each kind of match differently.

This page summarizes public rules without replacing them, and it is not legal advice.

Screen Your Next Client Today

Open your account and run the first PEP and list search, with its report.

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List screening Deep research PEP screening in Panama Services & Pricing

Guides on this topic:

What the Clinton List is What a PEP is Due diligence and KYC