AML, PEP and sanctions screening for Sierra Leone institutions
Updated May 2026 · 6 min read
KYC answers "is this person who they say they are?" AML screening answers a different question: "should we be doing business with this person at all, and is anything about them a money-laundering or sanctions concern?" The two run side by side, but they are not the same check.
This guide explains what AML screening, PEP checks, and sanctions lists mean, how they fit into onboarding, and where the honest limits are. It is general background, not legal advice — confirm current obligations with the Bank of Sierra Leone and your compliance team.
Identity verification versus screening
It helps to keep the two ideas separate:
- Identity verification (KYC) confirms the person is real and is who they claim — document, registry, and face match.
- Screening (AML) takes that confirmed identity and checks it against sanctions lists, watchlists, and politically-exposed-person data to see whether there is a risk worth a closer look.
You generally verify identity first, because screening a name you have not confirmed is far less useful. Once you know who the person is, you can screen them with more confidence.
Sanctions screening
Sanctions lists name individuals and entities that institutions are restricted from dealing with. Screening checks a customer against those lists. A genuine match is serious: it can mean you must not open the account, and may carry reporting duties.
The practical challenge is name matching. Names transliterate in different ways, spellings vary, and common names produce false matches. A screening result is usually a possible match to review, not an automatic verdict, so a flagged name needs a human to confirm whether it is really the same person before any action is taken.
PEP checks
A politically exposed person (PEP) is someone who holds, or has held, a prominent public position, along with close associates and family in some definitions. Being a PEP is not an accusation of wrongdoing. It signals that the relationship may carry higher risk and usually calls for enhanced due diligence: more scrutiny at onboarding and closer ongoing monitoring.
For Sierra Leone institutions this includes domestic public figures as well as foreign ones. What your policy requires for a PEP — additional approval, source-of-funds questions, senior sign-off — is something to define with your compliance team in line with current guidance.
Why screening is not one-and-done
Lists change, and a customer’s status can change too. Someone clean at onboarding may appear on a list later, or become a PEP after taking office. That is why screening is often repeated over the life of the relationship, not only at the start.
Two things worth settling in policy:
- How often do you re-screen existing customers?
- What is the workflow when a previously clean customer matches a list later?
Where MiProof fits
MiProof focuses on the identity side — confirming who the person is and keeping the evidence — which is the foundation screening relies on. Where screening checks are part of your flow, MiProof can record the screening outcome alongside the identity evidence so a reviewer sees the full picture for a case in one place. The decision on a flagged match stays with your compliance team. Treat any screening result as a prompt to review, not a final answer.
Common questions
Is being a PEP a reason to reject someone?
Not by itself. A PEP flag signals higher risk and usually means enhanced due diligence, not automatic refusal. Your policy decides what extra steps apply.
Does a sanctions hit mean we must close the account?
A genuine sanctions match is serious and can carry legal obligations, but most hits start as possible matches that need a human to confirm. Confirm the obligations and process with your compliance team.
How is screening different from a registry check?
A registry check confirms an identity is real. Screening takes that identity and checks it against sanctions, watchlists, and PEP data to assess risk. They answer different questions.
Want to see these checks on your own documents? Try a live demo or book a free process review and we will map them to your KYC tiers.