We spoke to Kayleigh Smale, founder of Smale Compliance about taking a proportionate approach to PEPs.
What proportionality looks like in practice
According to Kayleigh proportionality is not softer compliance. It’s clearer thinking. Start with three filters:
- Type of PEP and proximity to public funds
Domestic vs non domestic vs international organisation PEPs will start from different baselines. Go beyond the label: Backbencher is not the same as finance minister. Think about how close the role is to budget, procurement or licensing powers. Domestic PEPs may operate in a more regulated system than non-domestic PEPs, but the same principle applies: risk depends on the closeness to public money. - Role, reach and recency
Is the person current, within the 12-month definition, or former PEP. How much influence do they really have and is it fading? A former minister who left office 10 years ago is not the same as a current one signing off public contracts today. Make sure your assessment reflects that.Remember: the legal definition covers the last 12 months, but proportionality means looking beyond the label. Influence can linger, and if it does, so does risk.
- Context and connections
What is the jurisdiction, what is their financial story, and does it stack up? Do they have unexplained wealth, offshore structures, or intermediated funds? Or do they have a clear, credible SoW that matches their professional background?
From there, decide whether the risk is manageable with controls or unmanageable.
Manageable with controls might include:
- Source of wealth and funds evidenced and verified from primary documentation
- Adverse media resolved and recorded
- UK-centric income and assets with low exposure to corruption-prone sectors
- Payment flows that are simple and traceable
- Influence that is limited, historic or clearly declining
Unmanageable might include:
- Material ties to high corruption risk jurisdictions without plausible economic story
- Complex layering through opaque vehicles with no legitimate rationale
- High-risk role with direct control of procurement or licensing and weak SoW evidence
- Third parties insisting on routing funds in ways that defeat verification
- Close associates or family members clearly benefiting from the PEP’s role with no transparent justification
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About the author
Kayleigh Smale, Smale Compliance
Kayleigh Smale is the founder of Smale Compliance and a passionate advocate for making Anti-Money Laundering (AML) and compliance both practical and enjoyable. With over a decade of experience in the legal sector she has made it her mission to support law firms in navigating AML in a way that feels less like a box-ticking exercise and more like a meaningful part of doing business well.
Her work is guided by five key values: practicality, engagement, integrity, simplicity, and empathy. Whether delivering webinars, speaking at legal conferences, or developing clear and usable compliance policies, Kayleigh is known for her ability to bring clarity, confidence, and even a touch of fun to what can often feel like a daunting area.
She’s not just passionate about compliance, she’s passionate about helping others feel empowered and supported in getting it right.
About First AML
First AML comes from the perspective of both a technology provider, but also as compliance professionals. Prior to releasing, First AML’s all-in-one AML workflow platform, we processed over 2,000,000 AML cases ourselves. Understanding the acute problem that faces firms these days as they try to scale their own AML, is in our DNA.
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