Compliance Data Overview

Sanctions 1

Warnings and Regulatory Enforcement 4

Asia-Pacific 4
Europe and Middle East 7
Latin America and Caribbean 15
International 16
Family members 18
Close business associates 18
PEPs in State-Owned Enterprises (SOE) 18

Adverse Media 19

Fitness and Probity 19

Annexes 20
Annex I 20
Annex II 21
Annex III 21
Annex IV 22
Annex V 22

Current as at 31 April 2019

The Shufti Pro data provides a holistic solution to due diligence and compliance
requirements. Our global data sources are continuously updated, reflecting the
ever-changing risks to corporates and financial institutions in their dealings with global
counterparties. The data includes millions of profiles on high-risk individuals and
corporations worldwide. The adverse media set monitors millions of profiles of global
politically exposed persons (“PEPS”) and other higher-risk entities, including adverse
media relating to their activities.

This document is intended as a broad overview of the critical major global data
coverage areas rather than as an exhaustive listing of every source covered by Shufti Pro.
Sanctions
Entities sanctioned by the United States and other governments are statutorily
banned from doing business in or with the jurisdiction imposing the sanctions. For
example, American citizens, businesses, and governmental bodies are prohibited from
interacting commercially or financially with entities covered by US sanctions lists like that
issued by the Office of Foreign Assets Control (OFAC). Though a government's authority
is domestic, in these cases and technically relevant only to those institutions and
individuals subject to US jurisdiction, the nature of sanctions lists and the desire of
citizens and businesses to maintain their access to the US financial system makes this
power a multilateral tool by effect. UN members, meanwhile, are subject to an obligation
under international law to give effect to the UN’s sanctions in local law.

Banks and other institutions around the world, especially those wanting to maintain a
presence in the United States or the sanctioning country, have to monitor, if not honour,
lists. For instance, banks in Latin America had implemented the OFAC list tied to the
drug-trafficking cartels, often referred to in Spanish as "la lista Clinton" because of its use
during the Clinton administration. The OFAC power was an inherently international power
because of the importance of the American banking system and capital markets. Shufti
Pro allows you to monitor in real-time the full spectrum of critical sanctions lists. Shufti
Pro’s monitoring is inclusive of, but not limited to:
 List Name Region/Country

UN Consolidated - See Annex I United Nations

UN Security Council List of Designated Vessels United Nations

OFAC SDN List - See Annex II United States

OFAC Consolidated List - See Annex III United States

EU External Action Service - Consolidated List of European Union

Sanctions - See Annex IV
* formerly called European Union Sanctions List

European Council List of Designated Vessels European Union

European Council Restrictive Measures on Russian European Union

Entities

UK HM Treasury Office of Financial Sanctions United Kingdom

Implementation Consolidated List - See Annex V
* formerly called HM Treasury List

Canada OSFI Entity List Canada

Canada OSFI Person List Canada

Canada's Freezing Assets of Corrupt Foreign Officials Canada

Act

Public Safety Canada Listed Entities Canada

DFATD Canada Special Economic Measures Act Canada

Designations

Canadian Sanctions Justice for Victims of Corrupt Canada

Foreign Officials Act

DFAT Australia List Australia

France Tresor Direction Generale Liste Unique de Gels France

Federal Public Service National Financial Sanctions Belgium

Swiss SECO List Switzerland

Swiss Federal Council Freezing of Foreign Illicit Assets Switzerland
(Ukraine, Tunisia)

Singapore MAS List Singapore

Singapore First Schedule of the Terrorism (Suppression Singapore

of Financing) Act

India Ministry of Home Affairs Banned Organisations India

Israel Ministry of Defence Israel

Ministry of Finance Japan Economic Sanctions List Japan

Japan METI Export Control Security Division End User Japan

List

China Ministry of Public Security Terrorist List China

Russian ROSFIN Monitoring List (Extremism / Russian Federation

Terrorism)
Ukraine State Financial Monitoring Blacklist Ukraine

Norway Lovdata Judicial Laws Norway

Monaco Ministerial Orders Monaco

Netherlands Domestic Terrorist List Netherlands

US State Department Nonproliferation Sanctions United States

US Department of State Terror Exclusion List United States

US Department of State Cuba Restricted Entities List United States

Philippines AMLC Sanctions Resolutions Philippines

New Zealand Police Designated Terrorists New Zealand

Australian National Security Terrorism List Australia

Thailand Designated Persons List Thailand

South Korea Ministry of Strategy and Finance Sanctions South Korea

on Iran and North Korea

Malaysia Ministry of Home Affairs List of Sanctioned Malaysia

Entities
 Austrian National Bank (OENB) Sanctions Austria

UK Home Office Proscribed Terrorist Organizations United Kingdom

UK HM Treasury Ukraine Sanctions United Kingdom

* distinct from UK HM Treasury Office of Financial
Sanctions Implementation Consolidated List
Ireland Unlawful Organizations Sanction Laws Ireland

Sanctions List against State of Qatar’s support for Saudi Arabia, the UAE,
extremism and terrorism Bahrain and Egypt

United Arab Emirates List of Designated Terrorist United Arab Emirates

Organisations and Groups

Qatar National Terrorist Designation Lists Qatar

Vietnam Sanctions Ministry of Public Security Terrorism Vietnam

List

Warnings and Regulatory Enforcement

Legal enforcement data gives details of persons who have been, or are wanted
by national and international law enforcement bodies in connection with criminal activity.
Regulatory enforcement data covers regulatory actions against firms and individuals.

This information can be used when determining whether or not to engage in a

business relationship with potential customers, counterparties and suppliers. It might
equally be of use when making payments, and determining whether or not a payment is
being made in the furtherance of crime, or as part of a financial crime, such as a
money-laundering or insider trading scheme.

The Shufti Pro data set includes, without limitation, our analysis of the following
regional, national and international data-sets:

Africa
List Name Region/Country

Mauritius Independent Commission Against Corruption Mauritius

 Economic and Financial Crimes Commission Nigeria
Warnings and Convictions

Nigeria Securities Exchange Commission Nigeria

African Development Bank Debarment and Sanctions South Africa

South African Police Service South Africa

Asia-Pacific
List Name Region/Country

ASIC Disqualified Organisations Australia

Australia ARPA Disqualifications Australia

Australia ASIC Fake Regulators Australia

Australia ASIC List of Unlicensed Companies Australia

Australia ASIC Notices Australia

Australia AUSTRAC Civil Penalty Orders Australia

Australia AUSTRAC Infringement Notices Australia

Australia AUSTRAC Remedial Directions Australia

Australia AUSTRAC Remittance Registration Actions Australia

Australia Competition and Consumer Commission Australia
Infringement Notices
Australia Competition and Consumer Commission Australia
Public Warnings

Australia Disqualified Officers Australia

Australian National Security Terrorism List Australia

Canada IIROC Unpaid Fines Canada

China Banking Regulatory Commission China

Administrative Penalties

China Hong Kong Securities and Futures China

Commission Alert List
China Securities and Futures Commission China
Enforcements

Warnings China Economic Fugitives China

Hong Kong Monetary Authority Hong Kong

Hong Kong Most Wanted Hong Kong

Hong Kong Police Force - Wanted Persons Hong Kong
with Reward Notices

Hong Kong Securities Futures Commission Hong Kong

India CBI Reward List India

CBI Wanted List India

India CBI Red Yellow List India

India Competition Commission India

India NIA Most Wanted India

Security and Exchange Board Enforcement India

Japan Financial Services Agency Japan

Japan Financial Services Agency list of Unregistered Japan

Financial Trading Companies

Bank Negara Malaysia - Companies receiving Malaysia

Warning Letters

Bank Negara Malaysia - Invalid Licenses Malaysia

Bank Negara Malaysia Enforcement Actions Malaysia

Malaysia Securities Commission Administrative Malaysia

Actions

Malaysia Securities Commission Compounded Malaysia

Cases

Malaysia Securities Commission Criminal Malaysia

Prosecutions

Securities Commission Malaysia - Sanctions Malaysia

New Zealand FMA New Zealand

New Zealand FMA Management Bans New Zealand

New Zealand FMA Orders New Zealand

New Zealand Police New Zealand

New Zealand Putea Matua Reserve Bank New Zealand

New Zealand Serious Fraud Office New Zealand

Philippines Police Most Wanted Philippines

Philippines Securities and Exchange Commission Philippines

Singapore Monetary Authority Investor Alerts Singapore

Singapore Police Force Singapore

Thailand Securities and Exchange Commission Thailand

Japan Financial Services Agency Malicious Money Japan

Lenders List

Japan Aichi Prefectural Police Designated Gangsters Japan

List

Japan Shizuoka Prefectural Police Designated Japan

Gangsters list

Japan Exchange Group Disciplinary Actions Japan

Japan Financial Services Agency Illegal Financial Japan

Companies

Singapore Ministry of Manpower Employers Singapore

Convicted Under the Employment Act

Singapore Exchange Directors and Executive Singapore

Officers Watchlist

Singapore Exchange Group Public Disciplinary Singapore

Actions (Persons)

Singapore Exchange Group Public Disciplinary Singapore

Actions (Companies)
 Singapore Accounting and Corporate Regulatory Singapore
Authority Orders issued on Public Accountants for
Non-Compliance with PAOC order

Singapore Ministry of Law Fined Money Lenders Singapore

Singapore Monetary Authority Enforcement Actions Singapore

(Persons)

Singapore Monetary Authority Enforcement Actions Singapore

(Companies)

Singapore Competition Commission Anticompetitive Singapore

Agreements

Indonesia Financial Services Authority Unlicensed Indonesia

Entities

Malaysia Royal Police Wanted Persons Malaysia

Malaysia Anti-Corruption Commission Corruption Malaysia

Offenders

Malaysia National Bank Wanted Persons Malaysia

Philippines National Police Most Wanted Philippines

Europe and Middle East

List Name Region/Country

Special Inspector General For Afghanistan

Afghanistan Reconstruction

Albania State Police Wanted Albania

United Kingdom Anguilla Investor Alerts Anguilla

Austria FMA Investors Warnings List Austria

Azerbaijan Most Wanted Azerbaijan

Belgium Federal Police Wanted Belgium

United Kingdom Bermuda Monetary Authority Bermuda

Enforcement Actions
Court of Bosnia and Herzegovina Cases Bosnia and Herzegovina

United Kingdom Cayman Islands Monetary Authority Cayman Islands

Enforcement Actions
Cyprus Securities and Exchange Cyprus
Commission Warnings

Office for the Protection of Competition Czech Republic

Danish Financial Services Authority Warnings Denmark

Denmark Finanstilsynet Warnings Denmark

EU Most Wanted Europe

European Bank ineligible entities Europe

European Commission Banned Airlines Europe

FIN-FSA Finanssivalvonta Finansinspektionen Finland

Hellenic Capital Market Commission Greece

Guernsey Registry - Disqualified Directors Guernsey

and Involuntary Strike-Offs

Gazdasagi Versenyhivatal Decisions Hungary

Hungarian Competition Authority Hungary

Central Bank Warnings Ireland

Companies Registration Office Ireland

Ireland Revenue Defaulters List Ireland

FSC Disqualified Commission Isle of Man

Isle of Man Courts Ordinary Procedure Isle of Man

Isle of Man Employment Decisions Tribunals Isle of Man

srael Antitrust Authority Enforcement Activity Israel

Banca D’Italia Disciplinary Measures Italy

Financial Services Commission Public Statements Jersey

National Bank of Kazakhstan Kazakhstan

Commission de Surveillance du Secteur Financier Luxembourg

Malta Financial Intelligence Unit Malta

Administrative Penalties

Individual Voluntary Arrangement Register Northern Ireland

Pakistan National Accountability Bureau Pakistan

Polish Financial Supervision Authority Poland

Comissão Do Mercado De Valores Mobiliários Portugal

Romania Most Wanted List România

Saudi Arabia Washington Embassy Saudi Arabia

Finansinspektionen Sweden

Switzerland FINMA Unauthorized Services Switzerland

Tajikistan Ministry of Internal Affairs Wanted Tajikistan

Dubai Financial Services Authority Alerts United Arab Emirates

Court of Appeal Criminal Division United Kingdom

Disqualified Directors Register United Kingdom

FCA Final Notices - enforcement United Kingdom

FCA Unauthorised Firms and Individuals United Kingdom

FCA Warnings United Kingdom

National Crime Agency Most Wanted United Kingdom

Solicitors’ Disciplinary Tribunal United Kingdom

The Gazette - Insolvency Notices United Kingdom

UK Crimestoppers Most Wanted United Kingdom

United Kingdom FCA Unauthorized Binary Options United Kingdom

United Kingdom Serious Fraud Office United Kingdom

United Kingdom Deliberate Tax Defaulters United Kingdom

Austria Bundesministerium fur Innern Most Wanted Austria

Austria Bundesministerium fur Innren Wanted Austria

Belgium FSMA Warnings Belgium

Cyprus Central Bank Administrative Measures Cyprus

Cyprus Police Wanted Cyprus

France AMF Crypto Assets Websites Blacklist France

France AMF Forex Blacklist France

France AMF High Value Goods France
Non-Authorised Websites Blacklist
France AMF non-authorized binary options France
websites blacklist

France AMF Sanctions Decisions France

France Prudential Supervision and Resolution France
Authority Disciplinary Actions
Germany Bundesamt für Verfassungsschutz Germany
Prohibited Foreigner Extremist Organisations
Germany Bundesamt für Verfassungsschutz Germany
Prohibited Islamist Organisations
Germany Bundesamt für Verfassungsschutz Germany
Prohibited Rightwing Extremist Organisations
Germany Bundesanstalt fur Germany
Finanzdienstleistungsaufsicht Administrative
Measures
Germany Bundesanstalt fur Germany
Finanzdienstleistungsaufsicht Unauthorized
Businesses

Germany Bundeskriminalamt Wanted Persons Germany

Ireland Central Bank Enforcement Actions Ireland

Ireland Central Bank Prohibition Notices Ireland

Ireland Competition and Consumer
Protection Commission Criminal Court Ireland
Cases
Ireland Competition and Consumer Protection
Commission Criminal Court Cases Ireland
Organisations
Ireland Office of the Director of Corporate
Enforcement Disqualifications Ireland
Ireland Office of the Director of Corporate
Enforcement prosecutions Ireland

Ireland Revenue Commissioners Cash seizures Ireland

Ireland Revenue Commissioners Prosecutions Ireland

Italy Central Directorate of the Criminal Police
Most Wanted Italy

Luxembourg CSSF Administrative Sanctions Luxembourg

Malta Financial Services Authority
Administrative Penalties Malta

Malta Financial Services Authority Warnings Malta

Netherlands Authority for the Financial
Markets Warnings Netherlands
Netherlands Authority for the Financial
Markets Warnings from other regulators Netherlands
Netherlands Central Bank Enforcements
and Administrative Sanctions Netherlands

Netherlands Centrale Bank von Aruba Warnings Netherlands

Netherlands Police Most Wanted Netherlands

Norway Finanstilsynet Warnings Norway

Norway Finanstilsynet Warnings from foreign regulators Norway

Spain CNMV Unauthorised Entities and Warnings Spain

Spain CNMV Unauthorised Entities from
foreign regulators Spain

Spain CNMV Warnings from foreign regulators Spain

Spain Guardia Civil Most Wanted Spain

United States and Canada
List Name Region/Country

Canada Competition Bureau Canada

Alberta Securities Commission Decisions and Orders Canada

British Columbia Insurance Council Disciplinary Canada

Decisions

British Columbia Securities Commission Cease Trade Canada

Orders

British Columbia Securities Commission Denied Canada

Persons List

British Columbia Securities Commission Disciplined Canada

Persons List

Calgary Police Service Canada

Canada Border Services Agency Wanted Canada

Canada Chartered Professional Accountant of Ontario Canada

Canada Investment Industry Regulatory Organisation Canada

Canada Law Society Tribunal Canada

Canada Mutual Fund Dealers Association Canada

Enforcement Hearings

Canada OSFI Warnings Notices Canada

Canada Public Notices Financial Transactions and Canada

Reports Analysis Center

Canadian Securities Administrators Disciplined Canada

Persons

Canadian Securities Commission Canada

Canadian Securities Commission Investor Alerts Canada

Edmonton Police Service Canada

Manitoba Insurance Council Disciplinary Decisions Canada

Manitoba Securities Commission Canada

Montreal Exchange Disciplinary Decisions Canada

New Brunswick Financial and Consumer Services Canada

Tribunal

Newfoundland and Labrador Cease Trade Orders Canada

Nova Scotia Securities Commission Enforcement Canada

Proceedings

Ontario Financial Services Commission Canada

Ontario Financial Services Commission Enforcement Canada

Activities

Ontario Provincial Police Canada

Ontario Securities Commission Canada

Peel Regional Police Canada

Public Notice Of Administrative Monetary Penalties Canada

Québec Bureau de Décision et de Révision Canada

Québec Chambre De La Sécurité Financière Canada

Québec Secretariat of the Council of the Treasury Canada

Royal Canadian Mounted Police Wanted List Canada

Saskatchewan Financial Services Commission Canada

Cease Trade Orders
Saskatchewan Insurance Councils Canada
Disciplinary Decisions

Toronto Most Wanted Canada

Alabama Baldwin and Etowah County Inmates United States

Alabama Calhoun County Inmates United States

Alabama Cherokee and Franklin County Inmates United States

Alabama Department of Corrections United States

Alabama Fayette County Inmates United States

Alabama Medicaid Suspended Providers United States

Arkansas Department of Health Excluded United States

Providers List

Arkansas Real Estate Commission Warnings United States

Chicago Board Options Exchange Disciplinary United States

Connecticut Department of Social United States

Services Administrative Actions List

District of Columbia Excluded Parties List United States

FBI Most Wanted United States

FINCEN Money Laundering Concern List United States

Federal Deposit Insurance Corporation Failed United States

Bank List

Florida Agency for Healthcare Admin United States

Medicaid Sanctioned Providers
 Florida Department of Corrections United States

Foreign Agents Registrations United States

Georgia OIG Exclusions List United States

Guantanamo Bay Detainees United States

Hawaii Medicaid Excluded Providers United States

Inter-American Development Bank United States

Kentucky Medicaid Termination and Exclusion List United States

Louisiana Department of Health Hospitals United States

Exclusion List

Maine Medicaid Exclusion List United States

Maryland Department of Health Mental United States

Hygiene Exclusions List

Massachusetts Health and Human Services List United States

of Suspended or Excluded Masshealth Providers

Michigan Department of Community Health List United States

of Sanctioned Providers

Minnesota Department of Human Services United States

Excluded Provider Lists

Mississippi Gaming Commission Exclusion List United States

Missouri Department of Social Services Medicaid United States

List of Terminated Providers

Montana Excluded or Terminated Medicaid Providers United States

NYSE Non Compliant Issuers United States

NYSE Regulation: Disciplinary Actions United States

Nevada GCB Most Wanted United States

Nevada Gaming Control Board Excluded United States

New Jersey Office of the State United States

Comptroller Consolidated Debarment
Report
New York Office of the Medicaid Inspector General United States
List of Exclusions

Ohio Department of Corrections Wanted United States

SEC Trading Suspensions United States

US Air Force Fugitives United States

US Arizona Department of Insurance United States

US Army Most Wanted United States

US Bureau of Alcohol Tobacco Firearms United States

and Explosives Commission Most Wanted

US Consumer Financial Protection Bureau United States

US DEA Fugitives United States

US Department of Commerce Denied Persons United States

US Department of Housing and Urban United States

Development Limited Denials of Participation

US Department of State Consent Agreements United States

US FDA Clinical Investigators Disqualification United States

Proceedings

US FDA Debarment List United States

US FFIEC Failed Bank List United States

US Financial Industry Regulatory Authority United States

US Georgia Bureau of Investigation United States

US Immigration and Customs Wanted United States

US Indiana Most Wanted List United States

US Marshals Wanted United States

US Medicaid Exclusions Lists OIG LEIE United States

US Nasdaq Trader PHLX Disciplinary Actions United States

US OCC Enforcement Actions List Archive United States

US Office of the Comptroller of the Currency United States

US Pennsylvania General Services United States

Department Debarment List

US Postal Inspection Service Most Wanted United States

US Redding Most Wanted United States

US Rewards for Justice United States

US Securities and Exchange United States

Commission Unregistered Soliciting
Entities
US State Department AECA Debarments United States

US System for Award Management Exclusions United States

United States FINRA Disciplined Firms Taping Rule United States

United States National Credit Union
Administration Enforcements United States

United States OCC Enforcement Companies United States

United States SEC Fictitious Governmental
Agencies Main List United States
United States SEC PAUSE Impersonators Main List United States

United States SEC PAUSE Impersonators Main List United States

 Unverified List (UVL) - US Bureau of Industry
and Security" a SUA United States
United States Federal Deposit Insurance
Corporation Enforcements United States

Latin America and Caribbean

List Name Region/Country

Bahamas Central Bank Bahamas

Belize Warning Notices Belize

Bermuda Monetary Authority Bermuda

Brazil Civil Police Wanted Brazil

Brazil National Register of Punished Companies Brazil

CNEP

Brazil National Registry Of Ineligible And Brazil

Suspended Companies

Brazil Policia Federal Most Wanted List Brazil

Brazil Register of Non-Profit Entities CEPIM Brazil

Brazil Registration of Federal Administration Brazil

Expulsions (CEAF)

Brazil Warnings Polícia Civil Rio Grande do Brazil

Sul Wanted

British Virgin Islands Financial Services Commission British Virgin Islands

Chile Unidad de Análisis Financiero Chile

Colombian Financial Superintendence Colombia

Costa Rica Superintendencia General De Seguros Costa Rica

México Comisión Nacional Bancaria y De Valores Mexico

Mexico Banco De Mexico Penalties to Financial Mexico

Intermediaries
 Mexico Tax Administration Service Firms Issuing False Mexico
Invoices List (Companies)

Mexico Tax Administration Service Individuals Mexico

Taxpayers False Invoices (Persons)

Mexico Comision Nacional Bancaria y de Valores Mexico

Sanctions on Remittance Companies and Exchanges

Mexico Procuradoria General Most Wanted Mexico

Brazil Ministerio Publico Federal Operation Maus Brazil

Caminhos List

Brazil Comissao de Valores Mobiliaros- Irregular Brazil

securities intermediaries List (Persons)

Brazil Comissao de Valores Mobiliaros- Irregular Brazil

securities intermediaries List (Organizations)

Brazil Central Bank Disqualifications Brazil

Brazil Council for Financial Activities Control Punitive Brazil

Administrative Proceedings

Argentina Ministry of Justice Most Wanted Argentina

Argentina National Securities Commission Disciplinary
Resolutions Argentina
Argentina National Securities Commission Warning
Notes Argentina
Colombia Autorregulador del Mercado de Valores
Sanctions Colombia

International
List Name Region/Country

Debarred Entities Asian Development

Bank
International IOSCO Warnings International Organization
International Organization of Securities of Securities
Commissions Commissions (IOSCO)
 Wanted Listed Interpol

Debarred List World Bank

Politically Exposed Persons (“PEPS”)

A politically exposed person (“PEP”) is an individual who is or has been entrusted
with a prominent function by a local, regional, national or international governmental
body. Given the global mobility of PEPs, the Shufti Pro database covers high-ranking
government officials in every active jurisdiction. Shufti Pro provides a comprehensive and
widely-adopted source of structured intelligence on PEPs and heightened risk individuals
and organisations.

Shufti Pro use the Financial Action Task Force (“FATF”) definition of PEP and
PEP Categorisation. FATF is an inter-governmental body established in 1989 by the
Ministers of its member jurisdictions.

The FATF currently comprises 35 member jurisdictions and 2 regional

organisations, representing most major financial centres in all parts of the globe. The
objectives of the FATF are to set standards and promote effective implementation of
legal, regulatory and operational measures for combating money laundering, terrorist
financing and other related threats to the integrity of the international financial system.

Because of the risks associated with PEPs, the FATF Recommendations require
the application of additional AML/CFT measures to business relationships with PEPs.
These requirements are preventive (not criminal) in nature, and should not be interpreted
as meaning that all PEPs are involved in criminal activity, or even necessarily pose a high
risk of money laundering. Further legislation around the world, including the EU’s 4​th
money laundering directive, mandates enhanced due diligence requirements when
dealing with all politically exposed persons.

Risk Levels
The Shufti Pro PEP Definition and ranking is based on the FATF version:

Level 1 - Highest Risk

● Heads of state and government
● Members of government (national and regional)
● Members of legislatures (national and regional)
● Heads of military, judiciary, law enforcement and board of central banks
● Top-ranking officials of political parties
 ● Current or former senior official in the executive, legislative, administrative,
military, or judicial branch of a foreign government (elected or not)
● A senior official of a major foreign political party
● A senior executive of a foreign government owned commercial enterprise, being
a corporation, business or other entity formed by or for the benefit of any such
individual
● An immediate family member of such individual; meaning spouse,
parents, siblings, children, and spouse's parents or siblings
● Any individual publicly known (or actually known by the relevant financial
institution) to be a close personal or professional associate to one of the
individuals in this category.

Level 2 - Medium-High Risk PEPs

● Senior officials of the military, judiciary, and law enforcement agencies
● Senior officials of other state agencies and bodies and high ranking civil servants
● Senior members of religious groups
● Ambassadors, consuls, high commissioners

Level 3 - Medium Risk PEPs

● Senior management and board of directors of state owned businesses
and organisations

Level 4 - Low Risk PEPS

● Mayors and members of local county, city and district assemblies
● Senior officials and functionaries of international or supranational organisations

In addition, family members and close associates of PEPs are considered PEPs,
and can be risk-ranked as described below.

Family members
● A spouse; a partner (including a person who is considered by his national law as
equivalent to a spouse); children and their spouses or partners; and parents (ranked
at the same level as the PEP associated with but not higher unless the family
member in question is a PEP in his/her own right. In such cases, the political
position held by the spouse will determine his or her classification
● Siblings, and in some jurisdictions grandparents, grandchildren, other blood relatives
and relatives by marriage, are ranked at one level down from the associated PEP
● Relatives and close associates of PEPs can cause issues that pertain to financial
crime, as would-be criminals could use the family members of corrupt politicians to
move illicit funds.
Close business associates
● Any natural person who is known to have joint (or sole) ownership of legal entities or
legal arrangements known to have been set up for the benefit of a person who is a
PEP, or any other close business relations with a person who is a PEP.
● Close business colleagues and personal advisors/consultants to the politically
exposed person, as well as persons who derive clear, significant benefits from being
close to such a person. These associates are ranked at the same level as the
primary PEP
● Business associates who are not PEPs in their own right but who share a common
platform at a board level in non-SOEs, whether privately held or not. These
associates are ranked one level down from the primary PEP

PEPs in State-Owned Enterprises (SOE)

Whilst the FATF and other legislative directives mandate that a company should
be wary of conducting business with an executive of a state owned enterprise, Shufti Pro
has extended its dataset to include the boards of state owned enterprises. This will
enable a company apply extra due diligence if they are partaking in business
relationships with state-owned enterprises.

High Risk – Level 1 SOEs

● Businesses which are 51%-100% state owned

Medium-to-High Risk – Level 2 SOEs

● </=50% state owned and where government is represented on the company’s board

Medium Risk – Level 3 SOEs

● Subsidiaries of high risk and medium-to-high risk businesses as long as these
subsidiaries also fit the criteria defined therein relating to the ownership
structure and representation on the board
● Companies in which % of government control is not defined but there is
evidence of state ownership and the government is involved in the company
through its representation on the board

Low Risk – Level 4 SOEs

● State owned/controlled companies at local or municipal government level
regardless of % of ownership as long as government is represented on
the company’s board
Adverse Media
The Shufti Pro adverse media dataset is a state of the art, real-time structured data
feed of companies and individuals subject to adverse media. Monitoring thousands of
news sources, business and trade journals, in addition to local, regional and national
newspapers, the adverse media feed isolates and highlights any entities subject to a
range of adverse media.

The adverse media is categorised by risk type, and includes information about risk
age and risk stage. This encompasses media relating to accusations, arrest, trial and
exoneration. Risk Age includes the age of the adverse media. Risk type includes a
granular breakdown of the risk category, at the top level that includes narcotics, terrorism,
violent, and financial crimes. Adverse media profiles are enhanced by additional
identifying information (location; media text; date of birth; occupation) when available.

Fitness and Probity

Shufti Pro’s fitness and probity data set encompasses individuals who have
committed transgressions but who might not necessarily have committed offenses that
would lead them to be denied funds or bank accounts. It might however lead you to
reassess a potential business relationship with these entities.

Annexes

Annex​ ​I
UN Consolidated Sanctions​ list - includes the following UN Security Council Resolutions:
● UN ISIL (Da'esh) and Al-Qaida Sanctions List
● UN Security Council Resolution 1596 (2005) DR Congo List
● UN Security Council Resolution 1672 (2006) Sudan List
● UN Security Council Resolution 1718 (2006) North Korea List
● UN Security Council Resolution 1844 (2008) Somalia and Eritrea List
● UN Security Council Resolution 1970 (2011) Libya List
● UN Security Council Resolution 1973 (2011) Libya List
● UN Security Council Resolution 2009 (2011) Libya List
 ● UN Security Council Resolution 2048 (2012) Guinea-Bissau List
● UN Security Council Resolution 2134 (2014) Central African Republic List
● UN Security Council Resolution 2140 (2014) Yemen List
● UN Security Council Resolution 2196 (2015) Central African Republic List
● UN Security Council Resolution 2206 (2015) South Sudan List
● UN Security Council Resolution 2231 (2015) Iran List
● UN Security Council Resolution 2262 (2016) Central African Republic List
● UN Security Council Resolution 2270 (2016) North Korea List-Annex III
● UN Security Council Taliban Sanctions List
● UN SC Sanctions Committees Arms Embargoes

Exception: UN Security Council List of Designated Vessels is not included in their Consolidated list
and we cover it separately.

Annex II
OFAC SDN sanctions​ list - Specially Designated Nationals And Blocked Persons List
(SDN) by OFAC, US Treasury, covers the following active sanctions programmes:
● Balkans-Related Sanctions
● Belarus Sanctions
● Burundi Sanctions
● Countering America's Adversaries Through Sanctions Act of 2017 (CAATSA)
● Central African Republic Sanctions
● Counter Narcotics Trafficking Sanctions
● Counter Terrorism Sanctions
● Cuba Sanctions
● Cyber-related Sanctions
● Democratic Republic of the Congo-Related Sanctions
● Foreign Interference in a United States Election Sanctions
● Global Magnitsky Sanctions
● Iran Sanctions
● Iraq-Related Sanctions
● Lebanon-Related Sanctions
● Libya Sanctions
● Magnitsky Sanctions
● Non-Proliferation Sanctions
● North Korea Sanctions
● Rough Diamond Trade Controls
● Somalia Sanctions
● Sudan and Darfur Sanctions
● South Sudan-related Sanctions
● Syria Sanctions
● Transnational Criminal Organizations
 ● Ukraine-/Russia-Related Sanctions
● Venezuela-Related Sanctions
● Yemen-Related Sanctions
● Zimbabwe Sanctions

Annex III
The OFAC Consolidated sanctions​ list covers non-SDN sanctions designations under the
following programmes:
● Foreign Sanctions Evaders (FSE) List
● Sectoral Sanctions Identifications (SSI) List
● Palestinian Legislative Council (NS-PLC) list
● The ​List of Foreign Financial Institutions Subject to Correspondent Account
or Payable-Through Account Sanctions List (CAPTA List)​1
● Non-SDN Iranian Sanctions Act (NS-ISA) List
● List of Persons Identified as Blocked Solely Pursuant to Executive Order 13599
(the 13599 List)

Annex IV
The EU Consolidated Sanctions​ list covers the following programmes enforced by the EU
Security Council and maintained by the European External Actions Service:
● Arms embargoes
● Trade restrictions, such as import and export bans
● Financial restrictions
● Restricting movement, such as visa or travel bans

Exception: the EU Consolidated list does not include “European Council List of Designated Vessels
and European Council Restrictive Measures on Russian Entities” as this regime is coveraged as a
separate list.

Annex V
HM Treasury Sanctions​ lists covers the following regimes:
● Financial sanctions, Chemical Weapons
● Financial sanctions, Afghanistan

1​
List affected on March 14th 2019, replacing the currently defunct List of Foreign Financial Institutions
Subject to Part 561 (the Part 561 List).
 ● Financial sanctions, ISIL (Da'esh) and Al-Qaida organisations
● Financial sanctions, Belarus
● Financial sanctions, Burma
● Financial Sanctions, Burundi
● Financial sanctions, Central African Republic
● Financial sanctions, Democratic Republic of the Congo
● Financial sanctions, Egypt
● Financial sanctions, Eritrea
● Financial sanctions, Republic of Guinea
● Financial sanctions, Republic of Guinea-Bissau
● Financial sanctions, Iran (human rights)
● Financial sanctions, Iran (nuclear proliferation)
● Financial sanctions, Iraq
● Financial sanctions, Lebanon and Syria
● Financial sanctions, Libya
● Financial sanctions, Mali
● Financial sanctions, North Korea (Democratic People’s Republic of Korea)
● Financial sanctions, Somalia
● Financial sanctions, South Sudan
● Financial sanctions, Sudan
● Financial sanctions, Syria
● Current list of designated persons, terrorism and terrorist financing
● Financial sanctions, The Republic of Maldives
● Financial sanctions, Tunisia
● Financial Sanctions, UK freezing orders
● Financial sanctions, Ukraine (Misappropriation and Human Rights)
● Financial sanctions, Ukraine (Sovereignty and Territorial Integrity)
● Financial sanctions, Venezuela
● Financial sanctions, Yemen
● Financial sanctions, Zimbabwe

Important:​ - the HM Treasury Consolidated list covers entities designated under the following
regulations:
● ‘UK listing only’ – listed under TAFA 2010 only
● ‘Both UK and EU listing’ – listed under TAFA 2010 and under the EU’s asset freezing regime
● ‘EU listing only’ – listed under EU’s asset freezing regime. The prohibitions are found in
Council Regulation (EC) No 2580/2001 with penalties given by TAFA 2010.