1. Verify Basic Identifiers Against the PEP Match
Name: Check if the flagged name is identical or just a partial match (e.g., only first or last name matches).
Date of Birth (DOB): Confirm that the DOB of the individual matches the one associated with the flagged PEP.
Nationality or Address: Ensure the individual's location aligns with the flagged PEP’s details.
Action: If key identifiers such as DOB, nationality, or address do not match, this is a strong indicator of a false positive.
2. Cross-Check the Image of the PEP
Compare the photo of the flagged PEP from the database or system with the photo on the individual’s ID or verification record.
Look for clear mismatches in physical appearance, such as:
Different gender, age, or ethnicity.
Distinct physical features that make it clear the individual is not the flagged PEP.
Action: If the photos are clearly different, document the evidence and discount the match as a false positive.
3. Identify Additional PEP Data Points
Review details from the PEP database to confirm:
Position or Role: Does the individual currently or previously hold the role described (e.g., government official, judge)?
Jurisdiction: Is the flagged PEP from the same country or region as the individual?
Relationships: Is the individual flagged because of an association (e.g., family member or close associate)?
Action: If these additional data points do not align with the individual, the match is likely a false positive.
4. Validate the Information with Independent Sources
Use official records, public databases, or credible sources to confirm the individual's actual details, such as:
Employment history or LinkedIn profile.
Public records or articles showing their current position or role.
Reach out to the individual directly to clarify their role, address, or other details if needed.
Action: Document findings from independent sources or direct communication to support the false positive conclusion.
5. Document Your Analysis
Record all evidence used to discount the false positive, including:
Mismatched photos or physical identifiers.
Name, DOB, and nationality discrepancies.
Independent verification from trusted sources or direct contact with the individual.
Add a note in the system’s notes section when manually approving the potential PEP match to reflect the findings that led to the false positive conclusion.
Example Note: "Potential PEP flagged as [Name]. False positive determined due to mismatched DOB and nationality. Findings confirmed through public records and direct communication."
Example Scenario:
Potential PEP Match: Sarah Johnson flagged as a PEP due to a match with a sitting government minister of the same name.
Analysis:
Name Check: Matches, but Sarah Johnson’s DOB does not match the minister’s.
Photo Comparison: Image of the minister from the PEP database does not match Sarah Johnson’s ID photo (different gender and age).
Independent Verification: Public records confirm Sarah Johnson is a local business owner with no political ties. Sarah was contacted directly to confirm her occupation and address.
System Note: "Flagged as PEP due to name similarity. False positive confirmed through mismatched DOB, nationality, and photo comparison. Verified occupation via public records and direct communication."
Outcome: The match is discounted as a false positive, and findings are added to the notes section.