Global Data Sources
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First AML provides a holistic solution to due diligence and compliance requirements. Our global data sources are continuously updated, reflecting the ever-changing risks to corporates and financial institutions in their dealings with global counterparties. The data includes millions of profiles on high-risk individuals and corporations worldwide.
This document is intended as a broad overview of the critical major global data coverage areas.
SANCTIONS
Governments and international organisations impose economic sanctions to alter the decisions of other actors (state and non-state) who burden their interests and breach international norms. According to the UN: “Sanctions are meant to be a last resort when it comes to addressing massive human rights violations, curbing illegal smuggling or stopping extremism groups (…) being used to support peace efforts, to ensure that elections are held, or to demobilize armed groups”.
Entities sanctioned by the United States and other governments are statutorily banned from doing business in or with the jurisdiction imposing the sanctions. For example, American citizens, businesses, and governmental bodies are prohibited from interacting commercially or financially with entities covered by US sanctions lists like those issued by the Office of Foreign Assets Control (OFAC). Though a government's authority is domestic, and technically relevant only to those institutions and individuals subject to US jurisdiction, in this case the nature of sanctions lists and the desire of citizens and businesses to maintain their access to the US financial system makes this power a multilateral tool by effect. UN members, meanwhile, are subject to an obligation under international law to give effect to the UN’s sanctions in local law.
First AML allows you to monitor in real-time the full spectrum of critical sanctions lists.
WATCHLISTS
Watchlists comprise lists issued by law-enforcement or other regulatory bodies, containing individuals or other juridical entities. The lists are targeting law-breaking activities, as well as non-compliant behaviours at the international level, in particular jurisdictions or in specific industries. Distinct from sanctions, the watchlists do not serve as a diplomatic or governmental tool to achieve foreign policy goals or to amend decisions of state and non-state actors who threaten national interests or violate international norms.
WARNINGS AND REGULATORY ENFORCEMENT
Lists of individuals, legal entities, vessels, issued by relevant law-enforcement or regulatory bodies. Entities on such lists are either involved in law-breaking activities at international level or in particular jurisdictions, under investigation or found guilty of regulatory breaches in their operating industry, which may indicate a significant financial, compliance, or reputational risk.
This information can be used when determining whether or not to engage in a business relationship with potential customers, counterparties and suppliers. It might equally be of use when making payments, and determining whether or not a payment is being made in the furtherance of crime, or as part of a financial crime, such as a money-laundering or insider trading scheme.
The First AML data set includes regional, national and international data-sets.
FITNESS AND PROBITY
First AML’s fitness and probity data set encompasses individuals who have committed transgressions but who might not necessarily have committed offenses that would lead them to be denied funds or bank accounts. It might however lead you to reassess a potential business relationship with these entities.
Therefore this category encompasses lists of individuals and legal entities which have been disqualified or otherwise restricted from holding certain positions or participating in certain activities such as publicly-funded contracts due to regulatory or code of conduct breaches.
The First AML data set includes regional, national and international data-sets.
RELATIVES AND CLOSE ASSOCIATES (RCAs)
The FATF recommendations apply also to relatives and close associates of prominent entities, as these are also viewed as a potential source of risk - given their connections with the PEPs.
First AML considers the following categories of family members relevant from a PEP screening perspective (but not limited to):
- Spouse/ partner (including a person who is considered by his national law as equivalent to a spouse)
- Siblings/ Half-siblings
- Children/ Step-children and their spouses and partners
- Parents/ Step-parents
If an entity belongs to any of the above categories, it will be ranked at the same level as the PEP associated with, unless the family member in question is a PEP in his/her own right. In such cases, the political position held by the spouse will determine his or her classification.
ADVERSE MEDIA
The First AML adverse media dataset is a state of the art, real-time structured data feed of companies and individuals subject to adverse media. Monitoring thousands of news sources, business and trade journals, in addition to local, regional and national newspapers, the adverse media feed isolates and highlights any entities subject to a range of adverse media.
The adverse media is categorised by risk type, and encompasses media relating to accusations, arrest, trial and exoneration. Risk type includes a granular breakdown into 14 different categories, 8 of which cover all FATF, or EU Money Laundering Directive, predicate offenses. Adverse media profiles are enhanced by additional identifying information (location; media text; date of birth, publication date) when available.
POLITICALLY EXPOSED PERSONS (“PEPs”)
A politically exposed person (“PEP”) is an individual who is or has been entrusted with a prominent function by a local, regional, national or international governmental body. Given the global mobility of PEPs, the First AML database covers high-ranking government officials in every active jurisdiction. First AML provides a comprehensive and widely-adopted source of structured intelligence on PEPs and heightened risk individuals and organisations.
First AML aligns its PEP definition and categorization with the guidelines provided by the Financial Action Task Force (“FATF”). FATF is an inter-governmental body established in 1989 by the Ministers of its member jurisdictions.
The FATF currently comprises 37 member jurisdictions and 2 regional organisations, representing most major financial centres in all parts of the globe. The objectives of the FATF are to set standards and promote effective implementation of legal, regulatory and operational measures for combating money laundering, terrorist financing and other related threats to the integrity of the international financial system.
Because of the risks associated with PEPs, the FATF Recommendations require the application of additional AML/CFT measures to business relationships with PEPs. These requirements are preventive (not criminal) in nature, and should not be interpreted as meaning that all PEPs are involved in criminal activity, or even necessarily pose a high risk of money laundering. Further legislation around the world, including the EU’s 4th money laundering directive, mandates enhanced due diligence requirements when dealing with all politically exposed persons.
Risk Levels
The First AML PEP Definition and ranking is based on the FATF version:
PEP CLASS 1
- Heads of state
- Members of the national executive
- Members of the national legislatures
- Senior officials of military and law enforcement
- Senior officials of national agencies
- Board members of central banks
- Senior judiciary officials (national level)
- Top-ranking officials of political parties
PEP CLASS 2
- Board members of International Organizations (HIOs) & International Sports Federations
- Ambassadors, high commissioners and other top diplomatic positions
- Members of the regional executive
- Members of the regional legislatures
- Senior judiciary officials (regional level)
PEP CLASS 3
- Senior management and board of directors of state owned businesses and organisations
PEP CLASS 4
- Mayors and members of local government (sub-regional level)
As several regulations and best practice guidelines include as PEPs not only the entities that currently hold relevant positions, but also entities that have stepped out of office, First AML also takes a similar approach. Therefore, the First AML database also includes as PEPs entities that have held one of the above positions, but do not hold one anymore. In addition, family members and close associates of PEPs are considered PEPs, and can be risk-ranked as described below.
Our PEP dataset is refreshed every 24 hrs so updates will be available in the platform once every 24 hours, but this can be slightly longer depending on the update speed of the listing etc. First AML's stance is that once an individual is a PEP they will always screen as a PEP so previous listings will be shown in the platform. Alongside this we have legacy PEP data from prior to 2018 when legislation changed.
Current as of the 16th Dec 2024