Identification of foreign PEPs can be a nightmare for financial institutions and other service providers. It is hard to do proper customer due diligence due to the lack of official lists of PEPs and publicly accessible reliable information about their assets. In contrast to UN lists of terrorists and OFAC sanctions lists, there is no single accessible database of foreign PEPs.
To address these issues and to make it more difficult for Ukrainian PEPs to launder criminal proceeds through foreign banks, the Anti-Corruption Action Centre (AntAC), a Ukrainian NGO dedicated to combatting corruption, has created a free, publicly accessible database of Ukrainian PEPs.
The database, which is available at www.pep.org.ua, is, as far as we are aware, the first public national database of politically exposed persons and AntAC has been contacting foreign banks to inform them about the website and encourage them to use it.
Pep.org.ua currently contains 31,646 records of natural persons, including 12,825 who are PEPs by virtue of their prominent official positions and 18,821 immediate family members and close associates of PEPs. The database also contains information about 13,280 legal entities, including 3,753 state-owned enterprises and approximately 3,000 private companies beneficially owned by PEPs.
All the information is available in Ukrainian and English, including all possible transliterations from Cyrillic to Latin alphabet.
The key sources of information for the database are various public state registries and media records and, perhaps most importantly, a public register of electronic asset declarations of public officials in Ukraine. In 2016, Ukraine introduced a comprehensive e-declaration system which requires public officials to declare their income,assets, cash deposits and beneficial ownership in legal entities.
In creating the PEP database, AntAC has translated the relevant information, and cross-checked it against other available databases. AntAC analysts also monitor, on a daily basis, journalistic investigative reports, official information from law enforcement agencies, court records about suspicious assets, and public information about the connections and activities of Ukrainian PEPs.
If the reliability of this data can be confirmed, AntAC adds it to the database, with citations and links to the primary source material. All the relevant information is available in machine-readable format and can be easily incorporated into internal compliance systems.
We hope that this model will be replicated in other countries, a development which would create greater transparency and make it harder for kleptocrats to hide their ill gotten gains. For more information, please contact AntAc.
Tetiana Shevchuk, pictured above, is Legal Counsel and Project Manager, of the Ukrainian Anti-Corruption Action Center.