Special Interest Persons (SIP)
Special Interest Persons or SIPs are individuals who present a high risk to financial institutions due to being suspected or convicted of criminal activities. Just like Politically Exposed Persons (PEPs) or sanctioned individuals, SIPs typically require the bank to perform Enhanced Due Diligence and monitor their account for signs of suspicious activity.
Performing Special Interest Persons screening can often overlap with PEP or sanctions screenings, as these individuals are at a higher risk of being involved with financial crimes, however, this doesn’t have to be the case. They can also be screened by comparing the customer to a known criminal list or even by performing adverse media screening; for example, if they’ve only been suspected of a crime. But it’s generally a judgment call by the compliance officer handling the case.
High-risk individuals, persons of concern
-
-
SIP
Examples
A person applies to open a bank account. At first, the person doesn’t seem like a high risk as they don’t appear on any PEP or sanction screening lists. However, after an adverse media check, the bank finds that the person is under investigation for large scale money laundering. In accordance with their risk appetite, the bank decides to still open the account but first checks their Source of Wealth and Source of Funds, asks for added verification documents and keeps a close eye on their transactions for any suspicious activity.
FAQ
Are Special Interest Persons (SIPs) the same as Politically Exposed Persons (PEPs)?
No, while there can be overlap, SIPs and PEPs are different categories. PEPs are individuals who hold a position of a prominent public function and are not necessarily involved in any crime. SIPs on the other hand are individuals convicted or suspected of committing crimes, regardless of their title or position.
What criteria are used to identify Special Interest Persons (SIPs)?
The exact criteria for what classifies as a SIP can vary depending on the jurisdiction and the financial institution’s risk framework but generally covers individuals convicted or under investigation for crimes such as corruption, money laundering, human trafficking, terrorism, and tax evasion.
How are SIP screenings performed?
Unlike PEPs, SIPs can’t be easily accessed via aggregated lists. Instead, financial institutions use adverse media screenings, criminal databases, and internal communications.
