PEP and sanctions screening is one of the AUSTRAC obligations most often missed at audit. ComplyIQ delivers screening that operates per patron with a defined validity window, automatic re-screening, compliance officer match resolution, and PEP-flag-driven ECDD. The outcome is visible at the payout window without revealing anything to the patron.
Across independent reviews and AUSTRAC compliance assessments in the pub and club sector, PEP screening produces predictable findings. The underlying problem is structural: PEP screening cannot be a periodic admin task. It must be a continuous capability that fires when triggered, with results visible at the moment a high-value payout is being decided.
The program describes screening; the venue does not actually screen.
Screening runs as a quarterly batch; the 90-day validity window for individual patrons drifts past expiry.
Match candidates are dismissed by floor staff without compliance officer review.
Family members and close associates of PEPs are not screened – the obligation extends beyond the PEP themselves.
A confirmed PEP flag exists but ECDD never actually runs.
Six capabilities working together designed for the operational reality of a pub or club, not a bank.
Every patron screened gets a date-stamped result. The system tracks 90-day validity per patron, not against a calendar quarter. As a patron approaches expiry the system queues an automatic re-screen ahead of the next high-value payout.
Per-patron validity expiry tracked in days, not quarters
Auto-queued re-screen at trigger thresholds
Validity badge visible at the payout window
Audit trail of every screening event
Patrons are screened automatically at first identification, when a transaction or behaviour triggers ECDD, when the risk tier elevates to medium or high, or when a behavioural indicator justifies fresh screening. Continuous, not periodic.
Cumulative-payout threshold trigger
Risk-tier elevation trigger
Behavioural-indicator trigger
The AML/CTF Rules definition extends to spouses, parents, children, and known close associates of identified PEPs. ComplyIQ flags each category separately so the compliance officer can apply the right level of ECDD to each.
Domestic, foreign, and IO-organisation PEPs flagged separately
Family-member coverage (spouse, parents, children, in-laws)
Close-associate flagging with relationship context
Foreign PEPs default to higher-tier ECDD per AUSTRAC guidance
A returned match is a candidate, not a confirmation. The system routes every match to the compliance officer for review – verify against patron name and DOB, assess relevance, and record the decision (confirm, dismiss as false positive, or escalate to ECDD).
Match resolution wizard for the compliance officer
Floor staff cannot dismiss matches unilaterally
Decision recorded with timestamp and basis
Audit trail of every confirm/dismiss/escalate
A confirmed PEP flag triggers ECDD workflow at the next payout. Source-of-funds enquiry, source-of-wealth enquiry where applicable, compliance officer authorisation for significant payouts. The platform produces the structured decision record AUSTRAC asks for.
Auto-triggered ECDD on confirmed PEP match
Structured source-of-funds capture
Source-of-wealth enquiry where program prescribes
Compliance officer authorisation for high-value payouts
Australian and international sanctions lists screened on a continuous basis with any match routed for compliance officer review. Sanctions matches are treated more strictly than PEP matches – transactions involving confirmed sanctions matches are blocked and reported.
OpenSanctions integration for global coverage
Australian sanctions list (DFAT) screening
Confirmed sanctions match blocks transactions
Sanctions hit reporting workflow built in
A typical PEP match resolution from the moment the screening service returns a candidate through to the patron’s next payout. Patron-invisible throughout.
System screens the patron against PEP and sanctions lists at the trigger event.
Candidate match queued for compliance officer review – not visible to floor staff.
Compliance officer verifies name + DOB, assesses relevance, records confirm / dismiss / escalate decision.
Confirmed PEP triggers ECDD workflow at next payout – SoF enquiry, compliance officer authorisation.
Every screen, candidate, resolution, and ECDD action recorded with timestamp and decision-maker.
Section 123 of the AML/CTF Act creates a criminal offence for tipping off about an SMR, and the boundary applies to anything from which the patron could infer screening concern. ComplyIQ’s screening is invisible to the patron at every step.
Screening happens in the background. The patron is not asked to consent, complete a form, or answer screening-specific questions. The platform performs the screening based on identification data already captured
Match resolution happens in the compliance officer’s workflow, not at the payout window. The patron does not see escalation, queues, or unusual delays. The compliance officer reviews and authorises in the system.
Where ECDD is triggered, the patron-facing framing is policy-based (“our policy on payouts of this size is to confirm a few details”) – uniform across patrons in the same risk tier. The patron cannot infer they have been specifically flagged.
Floor staff see what they need to do their job – identification status, risk tier, escalation instruction – without seeing the underlying screening state. Section 123 containment is structural, not based on staff discretion.
Sanctions and PEP screening reads identification data from CDD, drives risk tier elevation, feeds ECDD triggers, and contributes to the audit trail. The screening module is one of seven that operate together as the ComplyIQ platform.
Identification feeds screening triggers and stores the patron’s risk tier.
Enhanced detection sensitivity applies to PEP-flagged patrons.
Suspicious activity from a PEP feeds the SMR pipeline with section 123 controls.
Every screen, match, and resolution recorded for the seven-year retention.
Smaller than most operators expect, larger than zero. Even a regional venue typically has a handful of patrons that screen as PEPs – current or former local councillors, judicial officers, senior public servants, and family members of the same. Until the venue screens, it does not know.
ComplyIQ integrates with established commercial screening services covering Australian and international PEP and sanctions data, including OpenSanctions for global sanctions coverage. Coverage, validity policies, and match-resolution workflow are documented in the venue’s program.
Foreign PEPs are typically rated higher-risk than domestic PEPs by AUSTRAC’s published guidance. ComplyIQ flags foreign PEPs separately and applies the higher-tier ECDD by default.
No. The screening is required by law and is performed without patron consent or knowledge. The patron is not aware of the screening unless a match triggers ECDD that involves them directly – and even then the framing is policy-based, not patron-specific.
ECDD applies. Source-of-funds enquiry where prescribed; compliance officer authorisation for the payout; documentation of the decision basis. The payout proceeds in the normal course; the compliance work happens in the system.
ID scanning captures identification at the door. PEP and sanctions screening checks the captured identification against curated lists, applies validity tracking, and triggers downstream ECDD. ID scanning is one input; screening is a continuous capability operating across the patron’s history with the venue.
Book a demo to see per-patron validity tracking, automatic re-screening, compliance officer match resolution, and PEP-flag-driven ECDD operating together – all visible at the payout window without revealing anything to the patron.
