Compliance

PEP: a politically exposed person and those close to them

PEP (Politically Exposed Person) is someone holding a prominent public or political position, or a family member or close associate of such a person. These players are identified through list screening, go through enhanced due diligence and need senior management approval. They are not barred from playing.

Yevhen SychovOctober 2026

Who counts as a PEP

  • Position: heads of state and government, ministers, members of parliament, supreme court judges, central bank governors, ambassadors, senior military officers, heads of state-owned companies and political parties.
  • Family: spouse, children and their spouses, parents. The exact scope is set by the market's law.
  • Close associates: a shared business or joint ownership of a company.

PEPs can be domestic, foreign or from international organisations. The status usually remains after the person leaves office, and the law also sets for how long.

How screening works

PEP screening is part of the AML programme. Players are screened against PEP and sanctions lists at registration and then regularly across the whole database: a player can take office after registering. A name match is not yet a PEP. It is confirmed by date of birth, country and KYC data.

PEP = a list match confirmed by KYC dataFor example, daily screening of a 50,000-player database returns 40 name matches. After checking date of birth and country, 2 genuine PEPs remain, and they are passed on for enhanced due diligence.

What the operator does

  • Enhanced due diligence: source of funds and source of wealth.
  • Senior management approval: a senior staff member decides whether to start or continue the relationship with the player.
  • Closer monitoring: lower alert thresholds on payments, regular profile reviews.
  • A recorded decision: who approved it, on what grounds and when the next review is due.

The set of measures depends on the licence and the market's law. But it is not a ban on playing: an account may be closed because of what the check finds, for example money with no clear source, not because of the status itself.

Common mistakes

  • Screening only at registration. A player became a minister a year later, but their profile still shows an ordinary player. Screening has to be regular and cover the whole database.
  • Refusing because of the status. The decision is based on the outcome of enhanced due diligence, not on the mere fact that the player is a PEP.
  • Checking only the politician. An MP's son or a minister's business partner goes through the same check.
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