To establish whether someone is a politically exposed person (PEP), verify their identity, confirm their public role and match that role to the applicable legal definition. The declarations register of Ukraine’s National Agency on Corruption Prevention (NACP, or NAZK in Ukrainian) can help identify declarations, assets and certain connections. A declaration alone does not establish PEP status, and an unsuccessful search does not rule it out.
Information checked as of 15 October 2026. The legal analysis was checked against Ukraine’s Law No. 361-IX, in the version dated 26 June 2026 that was in force on the review date. The workflow below is an editorial research method. For an entity subject to Ukraine’s anti-money laundering (AML) obligations, it supplements statutory and regulatory procedures. Other readers can use it to support counterparty due diligence or an analytical publication.
Who qualifies as a PEP, and why not every declarant does
Ukrainian law distinguishes domestic PEPs, foreign PEPs and persons performing public functions in international organisations. For a domestic PEP, check the specific office against Article 1(1)(37). Examples include members of Ukraine’s parliament, Cabinet members and their deputies, and Category A civil servants. These are examples, not the complete statutory list.
The obligation to file an asset declaration and the criteria for PEP status are different. A generic description such as “official”, employment at a public institution or the declarations register’s “high risk” filter cannot replace classification under Law No. 361-IX. Foreign and international organisation PEP checks also require sources from the relevant jurisdiction or organisation.
A PEP’s family member and a close associate are separate categories to identify. Do not describe them as officeholders unless they have held qualifying public functions themselves. PEP status is not evidence of corruption. FATF explains the preventive nature of these measures in its PEP guidance.
The NACP register and other sources for Ukraine PEP checks
Use each source to answer a specific question. A database flag is a research lead: trace it back to the underlying document, date and fact.
| Source | What to examine | What it does not establish |
|---|---|---|
| NACP declarations register | The declared role, income, assets, corporate interests and family information for the reporting period. | PEP status automatically, or the current accuracy of every disclosed fact. |
| Official appointment, dismissal or assumption-of-office instrument | The exact office, institution and period in which the function was performed. | Legal classification without matching the confirmed role to the law. |
| Current extract from Ukraine’s Unified State Register, ownership structure and company documents | Shareholders, ultimate beneficial owners (UBOs), control and changes over time. | Joint beneficial ownership with a PEP merely because someone is listed as a director. |
| State Register of Sanctions and the NACP corruption offences register | Separate sanctions and corruption-related findings. | Whether a person meets the PEP definition. |
FATF explicitly states that commercial and other databases alone are insufficient to meet PEP requirements. Examine update dates, coverage, identifiers and primary-source links. Several services reproducing the same publication do not provide independent corroboration.
Information to collect before searching
- Identity: full surname, given name and patronymic; previous surnames and known transliterations.
- Additional identifiers: date of birth, employer, office and region. Use only lawfully obtained information necessary for the check.
- Purpose: screening an individual, a company’s UBO, a family relationship or a business connection. These are distinct tasks.
- Time frame: the assessment date, periods in public office and declaration years. The most recent declaration alone cannot reconstruct a career.
- Research log: search query, source, URL, access date, document located and outstanding question.
A useful quality rule is to support an identity match with verified information beyond the name itself. This is an editorial recommendation, not a statutory minimum number of identifiers. Where the evidence is insufficient, leave the match unresolved.
How to conduct a PEP check: a practical workflow
1. Find declarations and distinguish people with the same name
Start with the full name in the public NACP register. If the search returns nothing, try individual name components, previous surnames and spelling variants. Then apply the available year and document-type filters. Compare the institution, role and other lawfully available identifiers with what is known about the subject.
Do not merge records solely because the names match. Record which details agree, which conflict and which are missing. If a date of birth is unavailable, do not substitute an assumption.
2. Establish the role and the timeline of public functions
Locate the official instrument on the website of the appointing authority or the body confirming the person’s mandate. Record the exact office title, instrument number and date, and the start and end of the public function. Distinguish the decision date from the date powers took effect where the document makes that distinction.
For a Ukrainian office, identify the relevant category in Article 1(1)(37). If the instrument cannot be located or the title does not allow a clear legal match, record what needs clarification. A candidate declaration alone does not show that the person was appointed.
3. Align reporting years, declaration types and versions
List documents by reporting period: annual, on leaving office, candidate and corrected declarations. Keep the filing year separate from the reporting year. For a corrected declaration, retain the current version’s link and explain whether the correction affects the assessment.
A change of employer between declarations does not establish an exact dismissal date. Treat it as a reason to locate the personnel instrument. Mark a missing year as an evidence gap, not a year with no income or assets.
4. Verify family and business connections
For each connection, record both parties, the relationship, the relevant period and the supporting document. For a company, follow the ownership chain through to individuals and check the historical date: today’s structure may differ from the structure at the time of a transaction.
Article 1(1)(42) covers, among other criteria, joint beneficial ownership, other close business relationships, and beneficial ownership of an entity or arrangement known to have been created for a PEP’s benefit. A photograph together, a social-media connection or employment at the same institution does not establish those criteria on its own.
5. Separate PEP status, source of wealth and source of funds
Source of wealth explains how a person accumulated their overall assets. Source of funds explains the particular money or assets involved in a transaction. These are separate questions addressed in paragraphs 86–88 of the FATF guidance published in June 2013.
In practice, for proceeds of an asset sale, compare the contract with the payment received; for an inheritance, examine the relevant inheritance documents; for earnings, check the period and evidence of payment. A public declaration can help frame the questions, but it cannot replace all documentation for a specific transaction.
In your working table, do not add savings balances to annual income, combine the declarant’s assets with relatives’ assets, mix currencies, or treat use rights as ownership. Record the date and basis of each value separately: a declared acquisition amount is not a current market valuation. Before interpreting a discrepancy, check for a comparison error.
6. Record the outcome and the next action
Select a working outcome: “category confirmed”, “match ruled out”, “no indicators identified in the sources checked” or “insufficient information”. These are suggested editorial labels, not official classifications. Where confirmed, specify whether the subject is a PEP, a family member or a close associate.
Then identify the next step: obtain an appointment document, clarify an identifier, verify a UBO or refer the evidence to the person responsible for AML compliance. A search report does not discharge all of a regulated entity’s legal obligations.
PEP family members: why the declaration is not enough
The family definition for Ukrainian AML purposes is in Article 1(1)(70) of Law No. 361-IX. It is not identical to the family scope used for NACP declarations. In particular, the AML list includes sons and daughters without a shared-residence condition. An adult child’s absence from a declaration therefore does not disprove their family relationship with a PEP for AML purposes.
The NACP’s explanation dated 13 January 2026 separately describes when adult children are included in a declaration. The practical lesson is to apply the relevant legal test rather than copying the declaration’s family section into a PEP file. A shared surname alone does not establish kinship either.
Former PEPs: what the 12-month rule actually means
The domestic PEP definition includes public functions performed in the past. In the current law, the additional measures and the conditions for discontinuing them appear in Article 11(14). References to paragraph 13 in older material must be checked against the version date.
After a person leaves the qualifying function, an obliged entity must consider continuing risks and apply the specified measures for at least 12 months. Once more than 12 months have elapsed, the measures in points 2–4 are discontinued when the cumulative conditions are met: transactions during that period were low risk, and the relationship shows no risks inherent in PEPs. A separate provision addresses family members and close associates.
The passage of time alone therefore does not justify “no longer a PEP”. Record the public-function history separately from the reasoning on continued measures. On 15 April 2026, the National Bank of Ukraine reminded banks to apply a risk-based approach. Domestic PEP status alone does not justify an automatic high-risk rating or refusal of service.
Three examples that change the assessment
The following are hypothetical training scenarios, not actual clients, investigations or DataClaris results.
Identical names, different people
A search finds a public servant’s declaration, while the client works in another sector. Different employers do not yet rule out a match: the person may have changed jobs. Additional identifiers or a verified biographical timeline are needed. Until then, record “insufficient information” and specify what would resolve it.
An adult daughter is absent from the declaration
The daughter lives separately and is not listed in the declaration’s family section. If kinship and the father’s PEP status are verified, the missing entry does not remove the AML family criterion. The conclusion should identify her as a family member, without attributing the father’s public office to her.
A former deputy minister left office more than a year ago
The dismissal instrument establishes the end of the public function. It does not automatically establish that additional measures should stop. Retain the historical office in the report; the obliged entity separately assesses the conditions in Article 11(14). An analyst should not substitute a count of elapsed months for that assessment.
How to document the PEP screening conclusion
Use this structure for a working report, populate it with the facts of the actual check and retain the evidence. Do not disclose unnecessary personal identifiers in a public publication.
| Field | What to record |
|---|---|
| Subject and date | Who was checked, why, and the date as of which the assessment applies. |
| Identity match | Verified matching details and unresolved inconsistencies. |
| Outcome and category | Working outcome; PEP, family member or close associate where confirmed. |
| Basis | The exact function or connection, relevant period, legal provision and document. |
| Sources | Direct URLs, document references, versions, reporting periods and access dates. |
| Limitations | Restricted records, missing years, unverified identifiers and uncorroborated reports. |
| Next action | Documents to obtain, the decision-maker and changes that should trigger a review. |
A defensible negative finding is: “As of the review date, no indicators of the relevant category were identified in the listed sources; the assessment is subject to the stated limitations.” This is more accurate than an unconditional “not a PEP” where the career history and connections could not be fully checked.
Common questions and limitations
Can PEP screening be done free of charge?
You can begin with the public NACP register and official instruments. That does not guarantee a complete check: some information may be unavailable, and identity or ownership questions may require additional documents. The price of a screening service does not determine whether its evidence is sufficient.
What does an unsuccessful declaration search mean?
Only that the document was not located using the query and information available. The NACP register warns that some declarations are excluded from public access during martial law. Alternative spellings or a document outside the period searched may also explain the gap. Record the specific limitation where it is known.
Does a declaration or PEP flag prove illicit enrichment?
No. Establishing a public function, examining asset provenance and reaching a legal finding of wrongdoing require different evidence. Distinguish verified facts, the subject’s explanations and your own analytical hypotheses. An unexplained discrepancy is a question to investigate, not a ready-made allegation.
Primary sources and dates
Sources checked on . An older guidance document’s publication date is not the version date of current Ukrainian legislation. Ukrainian-language legal texts are the source for the legal analysis in both versions of this article.
- Ukraine’s Law No. 361-IX of 6 December 2019, version dated 26 June 2026: Article 1, including points 37, 42, 47 and 70; Article 7; and Article 11(14).
- NACP Unified State Register of Declarations: public search, filters and access limitations.
- NACP explanation of a declarant’s family members, 13 January 2026. This explains declaration rules, not AML categories.
- National Bank of Ukraine: banks must avoid a purely formal approach to PEP customers, 15 April 2026.
- FATF Guidance: Politically Exposed Persons, Recommendations 12 and 22, June 2013: information sources, preventive measures, source of wealth and source of funds. This is methodological guidance, not Ukrainian legislation.
- Guidelines on managing business relationships with politically exposed persons, 2021, recommended on 31 May 2021 and published on the State Financial Monitoring Service website. Additional methodological reading; older statutory cross-references require verification.
- National Security and Defence Council: launch of the State Register of Sanctions, a 2024 announcement linking to the official register.
- NACP register of persons who committed corruption or corruption-related offences: a separate source for corruption-related checks.
What a completed check should establish
A PEP screening result should explain whose identity was verified, which function or connection was established, which legal provision applies and what remains unresolved. The NACP register is an important source in that process. A reproducible evidence trail and a clear next-action decision make the assessment useful.
More on working with open data: the DataClaris blog.