FINTRAC requires a determination for every individual on a deal: is this person a politically exposed person (PEP), and how do you know. BrokerPlus records that answer per applicant, whether it came from the client's own intake or your own attestation, on the deal's compliance record.
When You'd Use This
Open this whenever the compliance record shows an applicant with no PEP answer, or one that has expired. You'll also reach for it after a co-applicant joins the file - each individual needs their own answer, since one yes or no for the deal can't say which of three borrowers is the PEP.
What the Attestation Asks
Each individual applicant gets a row on the PEP register, inside the Know Your Client (KYC) and PEP check card, resolving to one of six answers: not a PEP, a domestic PEP, a foreign PEP, head of an international organization (HIO), a family member or close associate of one, or not yet determined. Entities don't get a row - it only applies to individuals. A client who filled out a BrokerPlus intake has usually already answered this, and their row shows what they said, that it came from their intake, and when - there's nothing to click over an intake answer. If they picked "unsure," the determination still sits with you, and the row stays outstanding until you resolve it.
Attesting for an Applicant Yourself
For anyone who hasn't answered, press Attest (or Update, once expired). The form asks two yes or no questions in order: is this client a PEP, and are they a family member or close associate of one. Yes to the first asks the type - foreign, domestic, or head of an international organization. Yes to the second asks where that person holds office, in Canada or outside it - leave it blank if unsure, which is a real answer rather than a guess. Both questions must be answered before the button unlocks. Finish by picking how you verified it - asked the client, reviewed documentation, prior knowledge, or other - and an optional note.
Sending the Form to the Client
If you'd rather the client answer directly, email them a PEP declaration form instead. Only the assigned broker or oversight can send one, the contact needs a name and email on file, and the link expires after 30 days. Once submitted, open or download the signed declaration as a PDF.
What a Positive Answer Means
A foreign PEP, or a family member or associate outside Canada, puts the client under FINTRAC's enhanced due diligence rules for as long as they hold that status. A domestic PEP or HIO only escalates that far if the risk-rating checklist separately scores them high risk. Whatever the answer, it expires three years after you record it (only "not yet determined" stays open), so a returning client eventually needs a fresh one.
Common Gotchas
- Sanctions freezes don't go through this form. A contact under an active freeze can't be attested until it clears - the register offers an escalate action instead.
- The jurisdiction question is only about a family member or associate, never the applicant's own PEP type - leaving it blank keeps the stricter, mandatory treatment.
- An "unsure" intake answer doesn't clear the row. It stays outstanding until a broker attests it.
What to Do Next
- Manage Enhanced Due Diligence Cases once a positive answer opens one.
- Tour the Compliance Record on a Deal for where this register sits among everything else.
- Complete the Risk Rating Checklist to see whether a domestic PEP or HIO answer needs to escalate.