Can a Business PEP Document be signed electronically?

Yes. Electronic signatures are generally enforceable under the federal ESIGN Act (15 U.S.C. ch. 96) and state UETA laws. Ensure intent, consent, attribution, and retention requirements are met; consumer-facing disclosures may be required in certain contexts.

What authentication level is appropriate?

Authentication depends on risk: low-risk cases may use email link and basic identity upload, while elevated-risk PEPs should use multi-factor authentication or verified ID checks and documented proofing steps.

When is notarization or RON needed?

Notarization is rarely required solely for PEP disclosures, but certain jurisdictions or legal filings may need notarized affidavits. Remote online notarization rules vary by state; verify with the relevant state notary authority before relying on RON.

How long should I keep PEP records?

Retain records for the active relationship and at least five years after termination to meet AML expectations; if records contain HIPAA-covered information, retain six years under 45 CFR §164.530(j).

What if the subject refuses to provide information?

Document all attempts to collect required data. Depending on your risk appetite and regulatory obligations, consider delaying onboarding, applying enhanced monitoring, or declining the relationship.

How to correct errors after submission?

Maintain a clear amendment process that logs who changed what and when. For material corrections, capture a dated statement from the subject and preserve both original and amended versions for auditability.

Business PEP Document

This template is fully customizable. Edit the text, fill out the fields, and send it for signature. Give it a try!

BUSINESS PEP DOCUMENT

This General Business Agreement ("Agreement") is entered into on by and between:

Client Name: Client Address: Service Provider Name: Service Provider Address:

RECITALS

WHEREAS, the Service Provider is engaged in providing enhanced due diligence, screening, and monitoring services relating to Politically Exposed Persons and related compliance matters; and

WHEREAS, the Client requires PEP screening, ongoing monitoring, and certification of beneficial owners and key personnel for the Client's business relationships and regulatory compliance; and

WHEREAS, the parties desire to set forth the scope, terms, confidentiality obligations, compensation, and other material provisions governing the provision of such services.

SCOPE OF WORK

The Service Provider shall perform the following services for the Client. The parties acknowledge that the specific deliverables, frequency of reporting, and information exchange procedures are set out below and may be supplemented by written attachments executed by both parties.

Detailed Scope of Work:

PAYMENT TERMS

As consideration for the Services, the Client shall pay the Service Provider in accordance with the following terms.

Total Fee or Fee Estimate: Payment Schedule and Milestones: Late Payment Fee: Payment Method:

TERM AND TERMINATION

This Agreement commences on and will continue until unless earlier terminated in accordance with this Agreement.

Notice Period for Termination (days):

Either party may terminate this Agreement for material breach following thirty (30) days' written notice and failure to cure the breach. Termination for convenience by either party requires the notice period specified above and payment for all Services performed through the effective date of termination.

CONFIDENTIALITY AND PEP OBLIGATIONS

Each party acknowledges that during performance it will receive Confidential Information of the other party. "Confidential Information" means non-public business, regulatory, or compliance information disclosed in any form. Each party shall: (a) protect Confidential Information using at least the same degree of care it uses to protect its own similar information, but no less than reasonable care; (b) limit disclosure to employees, agents, or subcontractors with a need to know and who are bound by confidentiality obligations; and (c) use the Confidential Information only for the purposes of performing this Agreement.

The Service Provider shall maintain records of all PEP screenings and monitoring conducted for the Client, including source data and identity verification steps, and shall provide such records to the Client upon request consistent with confidentiality obligations and applicable law.

Certification of PEP Status:

Client: Is the Client or any of its beneficial owners or key officers a Politically Exposed Person (PEP)?

Yes No Unknown / Will disclose if confirmed

Service Provider: Is the Service Provider or any of its beneficial owners or key officers a Politically Exposed Person (PEP)?

Yes No Unknown / Will disclose if confirmed

Each party represents and warrants that it has exercised reasonable efforts to identify whether it or its beneficial owners are PEPs and will promptly notify the other party in writing of any change in PEP status or discovery of undisclosed PEP relationships that could reasonably be expected to affect regulatory compliance obligations.

GOVERNING LAW

This Agreement shall be governed by and construed in accordance with the laws of without regard to conflict-of-law principles.

ENTIRE AGREEMENT

This Agreement, including any attachments or written amendments executed by both parties, constitutes the entire agreement between the parties with respect to the subject matter hereof and supersedes all prior and contemporaneous agreements, understandings, negotiations and representations, whether oral or written. Any amendment must be in writing and signed by authorized representatives of both parties.

Additional Provisions (optional):

Certification: By signing below, each signatory certifies that they are authorized to bind the party on whose behalf they sign and that the statements regarding PEP status and disclosures are true and correct to the best of their knowledge. Each party acknowledges that false statements, intentional omissions, or failure to disclose relevant PEP relationships may constitute a material breach of this Agreement.

Client:

By:

Date:

Service Provider:

By:

Date:

What the Business PEP Document Is and when it's used

The Business PEP Document is a standardized compliance form used to identify politically exposed persons (PEPs), ultimate beneficial owners, and related risk factors as part of Know Your Customer (KYC) and anti-money laundering (AML) due diligence. Organizations use it to collect verifying identity data, source-of-funds details, and declarations about public roles or foreign exposure. Although content varies by institution and risk tier, electronically completed Business PEP Documents remain legally acceptable in the United States when executed under ESIGN (15 U.S.C. ch. 96) or a state UETA framework, subject to regulatory exceptions.

Why a clear Business PEP Document matters for compliance

A consistent Business PEP Document reduces regulatory risk by documenting identity verification, seniority, and source-of-funds information needed for AML/KYC programs. Accurate, auditable records support regulatory examinations and reduce the chance of fines or onboarding delays.

Who typically completes and reviews the Business PEP Document

Teams and roles that interact with Business PEP Documents depend on organizational size and risk posture.

Compliance and AML teams responsible for enhanced due diligence and reporting
Onboarding officers and relationship managers who collect KYC/PEP data from customers
Legal or risk teams that validate data and approve elevated-risk relationships

In smaller firms a single compliance officer may handle all steps; in larger organizations duties are segregated to reduce conflict and ensure oversight.

Core sections every professional Business PEP Document should include

A useful Business PEP Document groups required information into clear sections so reviewers can rapidly assess risk and complete audit trails.

Subject identity

Full legal name, aliases, date of birth, and government ID details for the person under review; supports identity proofing and name-matching checks.

PEP status

Explicit declarative question about public office, senior political role, or close association with a current or former public official, including dates and jurisdiction.

Ownership and control

Ultimate beneficial ownership (UBO) disclosures for corporate customers, including percentage ownership and control relationships.

Source of funds

Concise description of income sources, transaction purpose, and origin of funds to assess risk and traceability.

Supporting evidence

List of documents provided (IDs, corporate filings, utility bills), verification methods used, and reference to third-party screening results.

Reviewer notes

Fields for reviewer name, date, risk rating, escalation steps, and required approvals for enhanced due diligence.

Step-by-step: completing a Business PEP Document

Follow these sequential steps to ensure a complete and auditable Business PEP record.

01

Prepare: Gather IDs and corporate records before outreach.
02

Collect: Send form and request digital copies of supporting documents.
03

Validate: Run sanctions and PEP screening checks and check ID authenticity.
04

Document: Record reviewer findings, risk rating, and escalation decisions.

How to set up an online Business PEP Document workflow

A simple digital workflow reduces manual handoffs; configure fields, authentication, and escalation before sending at scale.

Field	Configuration
Identity proofing	Enable ID upload and verification steps
Authentication	Use email + SMS or stronger methods for high-risk signers
Routing	Add conditional routing to escalate elevated-risk cases
Audit trail	Capture timestamps, IPs, and reviewer annotations

Technical capabilities needed for secure eSubmission and review

Select a platform that supports secure uploads, audit trails, and configurable authentication for high-risk KYC tasks.

File formats: PDF, JPG, PNG accepted
Access controls: Role-based permissions
Integrations: CRM and screening-service connectors

Platforms with API access and storage encryption make it easier to retain records, run bulk reviews, and integrate third-party screening services securely.

Typical routing: from collection to documented decision

A clear routing path ensures each Business PEP Document moves from intake to final disposition with required approvals.

Upload: Submit form and supporting documents to secure intake portal
Automated screen: Run sanctions and PEP screening services
Manual review: Compliance reviews matches and supporting evidence
Disposition: Approve, escalate, or decline with recorded rationale

Timing expectations and response windows for PEP screening

Timely data collection and review reduces onboarding delays and helps meet regulatory expectations for enhanced due diligence.

Initial collection window:

Collect PEP data at onboarding or at first substantive interaction

Screening turnaround:

Automated screening typically completes within minutes; manual review may take 1–5 business days

Escalation window:

High-risk cases should be escalated within 24–48 hours

Periodic review:

Re-screen PEPs and UBOs at periodic intervals (e.g., annually)

Record updates:

Update records promptly after material changes in status or ownership

Key milestones in a Business PEP review lifecycle

Track these numbered milestones to maintain an auditable compliance timeline.

01

Intake submitted

Form and documents received and logged in the system

02

Automated checks complete

Sanctions and PEP data returned with score

03

Human review started

Compliance officer assesses matches and documentary evidence

04

Final disposition

Decision recorded, with remediation or remediation plan if needed

Common pitfalls when preparing a Business PEP Document

Incomplete names or date-of-birth fields that prevent automated identity matching
Vague source-of-funds descriptions requiring follow-up documentation
Failing to document reviewer rationale for elevated-risk approvals
Using image uploads of poor quality that render IDs unreadable

Regulatory and operational risks of inaccurate PEP documentation

Regulatory fines: Civil penalties and enforcement actions for deficient AML/KYC controls

Onboarding delays: Reputational and revenue impacts from delayed account openings

Transaction holds: Suspension of transactions pending remediation or investigation

Legal exposure: Potential litigation from inadequate due diligence or false negatives

Sanctions risk: Failure to identify sanctioned persons can trigger severe penalties

Operational cost: Increased manual review hours and third-party screening fees

Essential data elements to capture on the Business PEP Document

Legal name: Full name on government ID

Date of birth: MM/DD/YYYY format

ID details: Document type and number

PEP role: Title and jurisdiction

Ownership stake: UBO % and relationship

Supporting docs: List of uploaded verification files

eSignature vendor pricing and capability snapshot for Business PEP Document workflows

This vendor snapshot highlights starting prices and a few capability markers relevant to secure PEP document workflows. Confirm vendor terms and HIPAA/BAA availability directly with providers.

	signNow	DocuSign	Adobe Sign	PandaDoc	HelloSign
Starting Price	$8/user/mo	$15/user/mo	$14/user/mo	$19/user/mo	$15/user/mo
Free Trial	Yes, 7-day trial	Verify	Verify	Verify	Verify
Bulk Send	Yes (Business Premium+)	Verify	Verify	Verify	Verify
Audit Trail	Yes	Yes	Yes	Yes	Yes
HIPAA Compliant	Yes (BAA required)	Verify	Verify	Verify	Verify
Envelope Cap	No envelope cap	100 envelopes/user/year	Verify	Verify	Verify

Real-world examples of Business PEP Document use

These short case summaries illustrate common scenarios and compliance outcomes.

Optica Ventures (Compliance Intake)

The firm integrated a standardized PEP form into onboarding to reduce manual checks

Screening flagged three high-risk matches requiring escalation
After process changes they documented reviewer rationale and reduced rework during audits, improving exam preparedness and transparency.

Martin Properties (Real Estate)

A property developer required PEP disclosures for high-value buyers

Staff used digital uploads and screening to verify UBOs quickly
The digital record and audit trail shortened closing review times and clarified source-of-funds for title insurers.

Practical tips to keep Business PEP Documents accurate and defensible

Adopt these practices to strengthen documentation quality and reduce review cycles.

Standardize field formats

Use MM/DD/YYYY for dates, require legal entity names for companies, and validate country and jurisdiction fields to improve automated match accuracy.

Require high-quality uploads

Specify image resolution and permitted file types for IDs; mandate front-and-back images where applicable to reduce verification friction.

Document reviewer decisions

Record risk ratings, rationale, and any conditions or monitoring requirements in the reviewer notes to support audits and supervisory inquiries.

Use layered authentication

Combine email verification with SMS or third-party identity proofing for higher-risk profiles to improve attribution and reduce fraud.

Frequently asked questions about the Business PEP Document

Answers to common questions when creating, signing, or storing Business PEP Documents.

Need help? Contact support

Can a Business PEP Document be signed electronically?
Yes. Electronic signatures are generally enforceable under the federal ESIGN Act (15 U.S.C. ch. 96) and state UETA laws. Ensure intent, consent, attribution, and retention requirements are met; consumer-facing disclosures may be required in certain contexts.
What authentication level is appropriate?
Authentication depends on risk: low-risk cases may use email link and basic identity upload, while elevated-risk PEPs should use multi-factor authentication or verified ID checks and documented proofing steps.
When is notarization or RON needed?
Notarization is rarely required solely for PEP disclosures, but certain jurisdictions or legal filings may need notarized affidavits. Remote online notarization rules vary by state; verify with the relevant state notary authority before relying on RON.
How long should I keep PEP records?
Retain records for the active relationship and at least five years after termination to meet AML expectations; if records contain HIPAA-covered information, retain six years under 45 CFR §164.530(j).
What if the subject refuses to provide information?
Document all attempts to collect required data. Depending on your risk appetite and regulatory obligations, consider delaying onboarding, applying enhanced monitoring, or declining the relationship.
How to correct errors after submission?
Maintain a clear amendment process that logs who changed what and when. For material corrections, capture a dated statement from the subject and preserve both original and amended versions for auditability.

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