Political risk begins not with a position, but with context
BLACKFILE checks how a public role, PEP status, business connections, environment and geography may affect a transaction, a bank, a reputation or the safety of a decision.
We separate formal status from actual exposure: we record confirmed connections, explain their significance and show which questions need to be resolved before the operation begins.
At the first stage it is sufficient to describe the decision and the role of the person being checked. Documents and sensitive data are not submitted.
PEP
SANCTIONS
CONFLICTS OF INTEREST
REPUTATIONAL EXPOSURE
The diagram shows an assessment model, not the data of a specific individual. Red marks only a material confirmed overlap.
02 / KEY POINT
The same contact can be a neutral fact or a material risk
The significance of a connection is determined by the person's role, timing, jurisdiction, the nature of the decision, and the quality of sources. A list of names or an automated PEP check is therefore not sufficient on its own. A contextual assessment is required: what is confirmed, how current it is, and what consequence is possible specifically for the client.
Status is a formal public function or PEP category. Connection is a direct, indirect, or historical intersection. Context is a transaction, bank, asset, public role, or dispute. Consequence is compliance, reputation, sanctions, or the safety of a decision.
BLACKFILE assesses each intersection along four dimensions: status, connection, context, and consequence.
03 / WHEN VERIFICATION IS NEEDED
Before an event after which explaining connections becomes harder
01
Opening an account or a major banking transaction
Prepare a verifiable explanation of status and sources of risk.
02
Инвестиция, партнерство или M&A
Verify the political exposure of key participants.
03
Owner's entry into the public sphere
Assess old connections, narratives, and vulnerabilities.
04
Work in a sensitive jurisdiction
Understand how local context changes the meaning of contacts.
05
Enquiry from compliance or a counterparty
Assemble a verifiable picture without extraneous data.
06
Reputational conflict
Establish facts, channels of dissemination, and escalation risk.
04 / WHAT IS CHECKED
Not private life, but factors relevant to the legitimate task
The check does not include unlawful access, reading private correspondence, covert surveillance, or collection of information unrelated to the stated purpose.
01
Status and lists
current and historical PEP status
sanctions and watchlist intersections
officially disclosed roles and interests
02
Connections and interests
corporate connections and beneficial participation
public conflicts of interest
political exposure of key partners
03
Context and consequences
litigation and regulatory context
media history and origin of persistent claims
geographic and sector factors
questions a bank, investor, or compliance function may raise
PERSONAL POLITICAL EXPOSURE
The decision is protected not by the volume of material collected but by the accuracy of answers to questions not yet asked
05 / EXPOSURE RINGS
Four levels of personal exposure
Select an exposure level to see how each element is recorded and flagged
Current and past positions, disclosed interests, official functions.
The diagram shows an assessment model, not the data of a specific individual. Red marks only a material confirmed overlap.
01Fact established: what exactly has been established and at what level of exposure.
02Period of relevance: when the connection arose and whether it is current.
03Source type: registry, court, official disclosure, or media.
04Level of confirmation: confirmed, requires clarification, or not confirmed.
05Possible consequence: compliance, reputation, sanctions, or the safety of the decision.
06Required next question: what needs to be closed before the operation begins.
Each item is marked as confirmed, requiring clarification, or unconfirmed. Red is used only for a material confirmed intersection. Fact and assessment are recorded separately.
06 / RESULT
A verifiable position instead of an undefined suspicion
The client receives material that can be worked with: sources, dates, and a confidence level for each point.
R-01 / RESULT
Executive summary and exposure profile
Key conclusions, PEP and political exposure profile, material intersections, and their significance for a specific decision.
R-02 / RESULT
Exposure Rings
Four levels of exposure: personal public role, direct business connections, indirect associations, and the context of the operation.
R-03 / RESULT
Timeline of roles and connections
Significant roles and intersections over time, with a check for sanctions and regulatory matches.
R-04 / RESULT
Origin of public claims
Where persistent media claims originated and which of them are confirmed by sources.
R-05 / RESULT
Impact assessment and next questions
Reputational and transactional impact, a list of items requiring confirmation by the client itself, and practical questions for legal and compliance.
R-06 / RESULT
Log of sources
Sources, dates, and confidence levels for each point. Fact and assessment are marked separately, and gaps are recorded rather than concealed.
This material is not a guarantee of a decision by a bank, regulator or counterparty and does not substitute for a legal opinion. The assessment reflects information established through lawful methods as of the agreed date.
07 / WHO THIS IS FOR
Who needs an assessment of personal exposure
CL-01 / CLIENT
Owners and UBOs
How to explain old connections to a bank before it asks. The result is a demonstrable explanation of status with a timeline and documents.
CL-02 / CLIENT
Executives of international companies
What a screening system will see at the next appointment. The result is an exposure profile and answers to likely compliance questions.
CL-03 / CLIENT
Investors and Family Offices
Whether parties to the transaction have political exposure. The result is a check of key persons in the structure before signing.
CL-04 / CLIENT
Legal and compliance teams
How to close a bank's questions about a specific client. The result is a log of sources and a breakdown of each match.
CL-05 / CLIENT
Banks and regulated counterparties, within their authority
How well an automated match reflects actual risk. The result is context for the match: the period, nature and current relevance of the connection.
CL-06 / CLIENT
Public figures and candidates for public roles
What old facts will surface upon entering the public sphere. The result is a map of vulnerable narratives and the origin of the claims.
08 / COMPOSITE EXAMPLES
How context changes the meaning of a connection
EX-01Historical LinkComposite example
Historical connection
Задача. The owner had an old public overlap with a politically significant person. The automated database showed the connection without context. The check established the period, the nature of the interaction and the absence of a current shared interest.
Результат. A demonstrable timeline and a list of documents were prepared that the client could provide to their compliance team.
EX-02Partner ExposureComposite example
Risk through a partner
Задача. Before an international transaction, political exposure was identified not in the client but in one of the parties to the structure. The significance of the connection depended on the jurisdiction and role in the operation.
Результат. The deal structure was revised, and additional questions were added to the due diligence.
The examples are composite and do not describe a specific client. Illustrative image: the client's identity is not disclosed.
09 / PROCESS
Related verification route
01
Purpose of the check
The operation, role, country and decision required
02
Legal boundaries
Authority, conflict of interest, need for consent
03
Identification
Exclusion of namesakes and false matches
04
Context of connections
Period, nature, directness and relevance
05
Impact assessment
Sanctions, compliance, reputation and the safety of the decision
06
Material for action
Conclusions, limitations and further questions
INITIAL→EXTENDED→INTERNATIONALThe cost is determined after review of the matter and identification of the subject. The result is not a guarantee of a decision by a bank, regulator or counterparty
10 / COST
Three formats for exposure assessment
The format depends on depth, geography and who will use the result
01
Initial exposure assessment
From €5,000
Usually 2-3 business days
Quick check of formal status and key overlaps before a specific decision.
Included
identification of the individual
PEP and sanctions overlaps
key public roles and connections
initial risk map
brief conclusion for decision-making
02Main engagement format
Extended personal check
10 000-25 000 €
Usually 5-10 business days
Full contextual assessment of exposure with analysis of connections, sources and impact scenarios.
Included
full context of roles and connections
Exposure Rings
corporate and transactional overlaps
media and regulatory history
assessment of impact scenarios
working session with legal/compliance
03
High-risk international project
Individual quote
Timeline determined after review of the task
Coordinated project for complex structures, multiple jurisdictions and updated factors.
Included
several countries and languages
complex structure of connections
coordination with external advisors
updates on material factors
separate executive briefing
11 / LEGAL AND ETHICAL LIMITS
Proportionality of the task matters more than the volume of information collected
BLACKFILE collects only the information necessary for a lawful purpose.
We do not examine private life out of curiosity, do not organize pressure, do not access closed accounts and do not publish unverified accusations.
No. What matters is the role, period, jurisdiction, nature of the transaction and related circumstances. Formal status is only the starting point of an assessment.
This depends on the purpose, legal basis and jurisdiction. Before starting, BLACKFILE verifies the admissibility of the task and the scope of data.
Only where the connection relates to the lawful purpose of the check and its analysis is permissible. Irrelevant information is not collected.
No. BLACKFILE verifies the match and context, but does not control the decisions of independent databases, banks or authorities.
The material can help prepare verifiable explanations. The requirements and decision of a specific bank are determined by the bank itself.
The composition of data, team access and method of transfer are agreed after the task is reviewed. Sensitive materials are not requested in the initial form.
14 / DIRECT CONTACT
Describe the decision for which exposure needs to be checked
At the first stage, do not submit a passport, documents, addresses or information of a private nature.
