14.22 How Frequently is PEP Data Updated?

PEP profiles are updated on both a periodic and ad-hoc basis.

Periodic review - according to the length of the term of the relevant position (if a term is undefined the default period is 5 years) + additional checks every 12 months. Election calendars for the specific position are also taken into account in this regard.

Ad-hoc review - prompted by specific events that come up during media monitoring, such as “snap” elections and re-shuffles (retirement, resignation, re-appointment, etc.).

In addition, it is worth noting that additional data may be made available, as the global information ecosystem is undergoing a structural transformation. Over the past several years, three concurrent developments have fundamentally altered how adverse media and risk-relevant data becomes available:

Digital archival acceleration. Newspapers, court registries, regulatory bodies, and government agencies worldwide are actively digitising historical records that previously existed only in print, microfiche, or localised databases.

AI-powered extraction at scale. Modern natural language processing (NLP) and machine learning models can now parse, classify, and extract structured data from unstructured sources (scanned PDFs, foreign-language publications, archived web content) at a speed and accuracy that was not previously possible. Data sources are deploying these technologies to process vast quantities of source material, which means historical information is being “discovered” by automated systems even though it may have been publicly accessible in some form for years (note, that even though the material is now “discovered” by AI, every piece is still vetted by human to assure full alignment with methodology.

Expanded source coverage. Data sources are continuously added to monitoring. As these new source feeds come online, they bring with them historical data from those sources that enters the screening ecosystem for the first time.

That is why additional data-points keep being added. In this regard, it is worth noting that regulatory guidance across major jurisdictions has consistently emphasised the importance of ongoing monitoring precisely because the information environment is not static. The Financial Action Task Force (FATF), the European Banking Authority (EBA), and national regulators recognise that screening is only as effective as the data universe it draws from; and that universe is expanding, casting an ever-wider net as data becomes available.