What are the common questions about PEP screening ?

  • Updated

PEP screening consists of identifying whether you, or a person linked to your business (legal representative, beneficial owner), are a politically exposed person. This is a regulatory obligation that applies to all financial institutions, regardless of the customer's profile.
 

What is the difference between a periodic review and a request related to my status as a Politically Exposed Person (PEP)?

These are two different checks, which can sometimes happen at the same time:

  • the periodic review applies to all business accounts and covers the company's activity and the identification data of the individuals linked to it (legal representatives and beneficial owners);

  • PEP screening (or an enhanced due diligence questionnaire on source of wealth) specifically concerns an individual identified as politically exposed, or linked to such a person, regardless of the company's profile.

If you receive both, they must be handled separately: responding to one doesn't automatically complete the other. If you're unsure about the exact nature of the request you received, contact our support team and provide the case number mentioned in the email.


Why am I subject to PEP screening, and what is a Politically Exposed Person?

A Politically Exposed Person (PEP) is someone who holds, or has held within the last few years, a prominent public function: for example, a Head of State, a member of government, a member of parliament, a member of a high-level judicial body, an ambassador, a high-ranking military officer, a director of a state-owned enterprise, or a senior official of a political party. This also includes their immediate family members (spouse, children, parents) and their known close associates.

This status is defined by French regulations (the Monetary and Financial Code).

Being identified as a PEP doesn't mean we have any suspicion about you: it's a regulatory status that requires us to apply enhanced due diligence (EDD) to the account concerned, which results in more frequent and more detailed checks than for a standard account.


I received an enhanced due diligence questionnaire on my source of wealth — what is it?

This questionnaire is part of the enhanced due diligence measures applied to Politically Exposed Persons and those close to them. It's designed to understand the origin and nature of your wealth (income, assets, sources of funding) so we can ensure that the funds passing through your account are consistent with your situation.

This is a regulatory obligation linked to your status as a PEP, or as someone close to a PEP, and not a request related to any doubt about a specific transaction. The information you provide remains subject to banking secrecy and is therefore strictly confidential. It is used solely for the purposes of our due diligence obligations.


Who needs to fill in the form or provide the documents?

The form must be filled in by the person explicitly named in the email or notification (usually the relevant legal representative or beneficial owner), and not by a shareholder, an agent, or an employee, even if they have access to the account. If the designated person is unable to do it themselves, contact our support team before the deadline to find out about the delegation procedure.


Is my account suspended for the entire duration of the review?

No. Your account remains fully active as long as you respond within the deadline. Suspension, and the resulting restricted access, only happens if the deadline passes without a response from you. This never happens before that, and never without prior notice.

 


What happens if I don't respond in time?

If the requested information and/or documents are not provided to us before the deadline, your account is suspended, and you'll only have access to our services on a restricted basis. 

In practice, debit and credit operations on your account are blocked. You can no longer make payments, transfers or direct debits, nor receive them, but you keep read-only access to your account, your history and your documents. 

Your funds remain secure and belong to you. They are not permanently blocked or seized. After 6 months of suspension and without a response from you to our requests, your account will be closed. You'll be notified of this decision, which will only take effect after the notice period set out in our Terms and Conditions. A funds return procedure will allow you to recover your assets.

Once the complete documents have been received and validated, full access to your account is restored.