What the label means
A special interest person, or SIP, is a label some screening products use for a group of results. Its scope depends on the product’s definition.
The AML/CTF Act does not use the term. It defines politically exposed persons instead.
Products can group different kinds of information under the label. There is no common legal test behind it, and not every SIP result has the same meaning.
AUSTRAC’s PEP guidance mentions databases and reports from third-party providers as one aid. Read the category definition for the service you use. The category name alone does not explain the underlying information.
Sources: Federal Register of Legislation: Section 5: definition of politically exposed person (the Act does not use the term special interest person); AUSTRAC: How to establish if an individual is a PEP: databases and reports from third party providers.
Examine the category, identity and source
A suggested review starts with the product’s category and the record that produced the result. Identify the reason for inclusion and any available source.
Then examine whether the record concerns the customer. Compare the available identifiers and record missing information. A similar name alone does not settle identity.
Examine what the source actually says and when it was published. An allegation, an investigation and a court finding describe different information.
A later correction or outcome may change the source’s meaning. Record uncertainty rather than treating the profile summary as a final finding.
Source: DFAT: Date of Birth; Place of Birth; Citizenship; Address; Additional Information.
- Provider category
Read the definition and the reason for inclusion.
- Identity
Examine whether the record concerns the customer.
- Source information
Separate allegations from findings. Examine later information.
- Next action
Record the evidence, uncertainty and responsible person.
Read the record before deciding
Suggested review process. A screening label alone does not establish identity, guilt or the required action.
Follow the process from top to bottom.
Keep PEP and sanctions questions separate
Politically exposed person, or PEP, status concerns public responsibilities and specified connections to people with those responsibilities. Sanctions raise separate questions about applicable restrictions.
A screening product can group different information under SIP. That grouping does not replace the relevant PEP or sanctions assessment.
The same applies to adverse media. The presence of a report does not establish that its subject committed an offence.
Sources: AUSTRAC: Overview of PEPs; How to establish if an individual is a PEP; DFAT: Opening guidance; Listing Information; Instrument of Designation; Targeted Financial Sanction.
Invented example: an unresolved identity
A reviewer receives a possible SIP match. The profile has too little identity information to confirm that it concerns the customer.
The reviewer records the category, available identifiers and missing information. The reviewer seeks suitable evidence under the business’s procedure.
The file keeps the match unresolved while the evidence is incomplete. It does not describe the customer as an offender or treat uncertainty as clearance.
Source: DFAT: Date of Birth; Place of Birth; Additional Information.
Record the reason for the next action
A useful record keeps the category, source, identity decision and remaining uncertainty together. It states the next action and who is responsible.
The customer-risk article explains how to record the implications of relevant evidence. A SIP label alone does not assign the customer’s final risk rating.
Source: AUSTRAC: Record keeping.