All customers must be screened against a reliable third-party database of PEPs,
their family members and known close associates:
During on-boarding (prior to any transactions taking place)
On an on-going basis, where any change in status is updated within 24 hours
10.1 Importapay Policy Treatment for PEP Individual
Relationships with Politically Exposed Persons (PEPs), including their family members and known close associates, are classified as high-risk. Based on Importapay’s current risk assessment, customers identified as PEPs are not accepted as a matter of standard practice. However, where a PEP relationship is identified, the customer may be accepted or retained only following enhanced due diligence and with the documented approval of senior management and close monitoring.