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PEP Match Disambiguation

Case KYC-C4D7 • GreenField Holdings Ltd HIGH PRIORITY

Is this the same person?

Sanctions Agent matched UBO "Schmidt A." against EU PEP database with 82% confidence. Compare and decide.
OUR CLIENT (UBO)
Full NameSchmidt, Andreas
Date of Birth1988-07-15
NationalityGerman
OccupationCTO, NordTech GmbH
AddressMunich, Germany
ID DocumentDE passport #87654321
UBO Share30% of GreenField Holdings
SourceAgent: CorpAssist AI
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PEP DATABASE RECORD
Schmidt, AndreasFull Name
1965-04-12Date of Birth
GermanNationality
Former State Secretary, BMIPosition
Berlin, GermanyAddress
—ID Document
Active 2010-2019PEP Period
EU PEP List (updated 2026-03-15)Source
Match Confidence
82% Name-only match. DOB, occupation, and address diverge significantly.
Auto-dismiss
below 60%
Auto-confirm
above 90%
0% — No match60%82% (this case)90%100% — Exact match
Agent Analysis — Why 82%?
🟢 Full name: exact match — "Schmidt, Andreas" matches 100%. Common German name, ~14,000 people in Germany with this exact name. +40pts
🟢 Nationality: match — Both German nationals. +15pts
🔴 Date of birth: 23-year difference — Client: 1988, PEP: 1965. This is the strongest differentiator. If same person, would require extreme age discrepancy in one record. -30pts
🔴 Occupation: no overlap — Client is CTO of a tech company. PEP was state secretary at German Interior Ministry. Different career paths. -15pts
🟡 City: partial match — Both in Germany but different cities (Munich vs Berlin). Weak signal. +2pts
🤖 Agent recommendation: Likely different person. DOB mismatch (23 years) combined with entirely different career trajectory. Name match alone is insufficient — "Schmidt, Andreas" is a common German name. However, cannot auto-dismiss (score > 60% threshold) — requires human confirmation. REVIEW
Similar Past Decisions (your team)
Different person Mueller, Hans — name match, DOB 15yr diff — dismissed by Ana M. (Jan 2026) Score: 79%
Different person Popescu, Ion — name match, same country, different city — dismissed by John R. (Feb 2026) Score: 75%
Same person Kovacs, Peter — name + DOB + city all matched — confirmed by Ana M. (Mar 2026) Score: 96%
Your Decision
✅
Different Person
The PEP record is not our client. Dismiss the match and continue processing.
⚠️
Same Person
Confirm PEP status. Triggers Enhanced Due Diligence (EDD) per EU AML Directive.
❓
Ask Client
Send human prompt to client for documentation proving they are/aren't the PEP.
Justification (required)
DOB mismatch
Different occupation
Common name
Client confirmed
Multiple matches
Your decision + justification will be logged in the tamper-evident audit trail
Decision Recorded