Senior manager approval before you take on a PEP

People search “PEP senior management approval AML” when a two-partner firm discovers a customer is a politically exposed person and wants the compliance line on the program to count as approval. Checked against AUSTRAC’s politically exposed persons page on 4 October 2026. This is general information, not legal advice. This page does not reproduce that guidance. The wider measures sit on enhanced customer due diligence. The officer role is a different hat, on the AUSTRAC compliance officer. The sector map is /tranche-2.

Approval is a named person and a time

A politically exposed person is a customer type the program already has a path for. Part of that path, where the program requires it, is approval by senior management before the designated service goes ahead. AUSTRAC’s PEP page is the frame. This page does not reproduce it and does not decide who is a PEP.

In a two-partner firm the same human may hold more than one hat. The approval line still names the senior-manager hat, the date, and the file. A compliance-officer signature is not that line unless the program says this person holds both hats and you record which hat was used.

• Approve before the service. An approval written after settlement describes a decision you did not make in time. The program’s sequence is the sequence.
• Name the senior manager. “The partners” is not a name. Write the person who can approve, and who covers leave.
• Separate the officer. The compliance officer oversees the program. Senior management approves the PEP where the program says so. Do not collapse the titles to save a line.
• Keep the check beside it, not instead of it. Verification can still be required. The result does not substitute for the approval, and the approval does not substitute for the check.

Hats on a PEP file

Read the file in order. If the approval is missing, the later pages do not repair it.

Where the PEP approval page stops

This page is the approval step. It is not the whole enhanced-due-diligence note and it is not the officer’s job description. Those are enhanced customer due diligence and the AUSTRAC compliance officer.

What the client pays

On FreeAML the firm suite is A$0. The firm emails the client a link. Verification is client-pays. On the public list a personal KYC check is A$20 and a company or trust KYB check is A$40. Use KYB when the customer is a company or a trust. Senior-manager approval of a PEP is not included in the firm suite, and a check result is not that approval. Confirm the live amounts on FreeAML pricing. FreeAML does not approve a politically exposed person or appoint your senior manager.

Frequently Asked Questions