PEPs, Sanctions & Adverse Media: How to apply Integrity Due Diligence

Introduction

The modern business environment has transformed significantly, and background screening has become a fundamental element of responsible partnership. Acknowledging the critical role of integrity due diligence, most organizations now incorporate background screening for high-risk individuals into their hiring and partnership procedures. This trend reflects an increased recognition of the need to base these hiring and partnership decisions on thoroughly verified reliable information.

The importance of thorough background screening becomes even more critical when hiring for high-stakes roles such as senior leadership positions or when onboarding promoters, founders, or key partners who wield significant influence. A single poor judgment in these areas can have outsized, long-lasting consequences for the organisation.

Who are high-risk individuals?

Key leadership are high-risk individuals due to the substantial influence they hold over an organisation’s critical decisions. According to the 2024 Workplace Culture Index, toxic leadership alone drives a 46% increase in employee turnover, resulting in substantial recruitment costs and lost productivity. In these high-risk hires, comprehensive background screening and rigorous due diligence are not just best practices; these are an essential risk-mitigation strategy.

When these high-risk individuals are involved in alleged lapses in judgment, it can translate into significant legal, reputation, and operational risks for the entire organisation. Senior leadership conduct directly shapes company culture, impacts employee morale, and can attract scrutiny from regulators, investors, and the public, as seen in recent examples.

Red flags to look for in high-risk individuals

  1. Global sanctions: Check if the individual is listed on any international sanctions lists, which could indicate involvement in illegal or unethical activities, posing serious compliance risks. 
  2. Adverse media: Look for negative media coverage that highlights criminal behaviour, ethical violations, financial misconduct, or other reputation risks. 
  3. Political Exposure (PEP): Identify if the individual holds or has held a prominent public position, increasing the risk of corruption or undue influence.
  4. Disputes: Investigate any ongoing or past disputes, whether legal, financial, or personal, that could affect their reliability or integrity.
  5. Affiliations: Review associations with questionable organisations, companies, or individuals that might suggest conflicts of interest or unethical behaviour.
  6. Litigation checks: Conduct thorough legal background checks to uncover any history of lawsuits, criminal charges, or other legal proceedings that could impact their suitability for leadership or partnership roles.

How to manage high-risk individuals?

  • Identify the risk: Flag PEPs, high-risk countries, significant adverse media, complex structures, or unusual activity.
  • Collect more data: Verify identity, beneficial ownership (UBO / SBO), source of funds, business relationships, and check sanctions/adverse media in depth.
  • Analyse thoroughly: Look for red flags, inconsistencies, or hidden risks.
  • Decide & document: Approve with controls, restrict, or decline; keep full audit trail.
  • Ongoing monitoring: EDD isn’t a one-time event; establish continuous oversight through periodic reviews and automated alerts for changes like new sanctions or adverse media. Adjust risk ratings dynamically as needed.

Want to see how screening works in practice?

Check out our Case Study on Senior Professional Screening to learn how we manage risks in high-stakes leadership hires with robust due diligence.

Conclusion

Thorough background screening and enhanced due diligence form the bedrock of safeguarding organisations against the risks posed by high-risk individuals, such as founders, promoters, and key leaders.

By proactively identifying red flags, companies can make informed decisions that protect their integrity and foster sustainable growth. Prioritising these practices not only ensures compliance but also builds a resilient foundation for long-term success in today’s complex business landscape.

Learn how our background screening can help manage high-risk individuals.

Contact us for more details on our due diligence services.

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