Risk designations

A risk designation is a flag on a customer or counterparty saying “treat this one with extra care”, and why. Rules read designations — a PEP’s large transfer gets a closer look — and escalation policies route on them too: cases about a PEP can open straight at level 2.

Why designations matter

International AML standards require enhanced due diligence for certain kinds of customer: politically exposed persons, anyone connected to sanctions, customers you have assessed as high risk. Designations are how SpeculaPro knows who those customers are, so that the rules and the case workflow can treat them differently.

Types

Type	Meaning	Example
pep	Politically exposed person — someone who holds or recently held a prominent public role	A deputy minister, a senior judge, the CEO of a state-owned enterprise
pep_rca	A relative or close associate of a PEP	The minister’s spouse, or a business partner
sanctioned	On a sanctions list	A person on the UN Security Council consolidated list
high_risk	Assessed as high risk by your institution	A money-service business with weak controls
adverse_media	The subject of credible negative news	A trader named in a fraud investigation in the press
watchlist	On your own internal watchlist	Someone previously exited for suspicious activity
custom:<key>	Your own type, lowercase with underscores	custom:shell_company_suspect

A PEP designation can also carry a class:

PEP class	Meaning
domestic	Holds a prominent role in your own country
foreign	Holds a prominent role in another country
international_org	Holds a senior role in an international organisation

A PEP is not a suspect

Being a PEP is not wrongdoing. PEPs are flagged because their position makes them a target for bribery and corruption, so their accounts need more scrutiny — not because anyone has done anything wrong. Case notes should reflect that.

What a designation records

Field	Meaning
Subject	The customer or counterparty
Type and PEP class	As above
Source	manual for every designation today, including one set by a confirmed screening match. That one says so in its reason (Confirmed screening match against …) and carries the match and the list entry in its evidence
Source reference	Not used today
Reason	Required, 3 to 2,000 characters. Why the designation applies, with the source you relied on
Evidence	Optional. Up to 10 links to the public sources you relied on (a gazette notice, an official register, a news article), your own file reference, and notes
Valid from / valid to	When it applies. Valid from is the moment you add it, or a later time set through the API (never earlier: rules have already run without it). Valid to is optional: a PEP who left office might be designated for a further period afterwards
Created by	Who added it
Revoked at, by, reason	Filled in if it is revoked

A designation is active while it isn’t revoked, valid from has arrived and valid to (if set) hasn’t passed. On the customer’s profile, one that hasn’t started yet is marked scheduled (and can be removed before it starts), one whose valid to has passed is marked ended, and a revoked one is marked removed. A subject can’t have two designations of the same type whose periods overlap; one that ends exactly when the next begins is fine.

Record the evidence, not just the conclusion

An examiner who asks how did you know? months later needs to reach the source. Add a link to each public source and the reference of your own due-diligence file when you add the designation; the profile shows them under the reason. Evidence is recorded when the designation is added and can’t be edited afterwards. Link only to public sources: everyone who can open the profile sees the links.

How to add a designation

Adding and revoking designations needs designations.manage — the Senior analyst and MLRO roles have it.

1. Confirm the match. Make sure the person or business really is the one on the list or in the news — same name, date of birth, ID number or registration. A wrong match is worse than none.
2. Choose the type, and for a pep or pep_rca the class. A class on any other type is refused.
3. Write the reason, and record the evidence: where you found it and what it says, with links to the sources and your file reference.
4. Decide on an end date. Leave valid to empty if it applies until revoked.
5. Save it. Rules read designations afresh for every batch of transactions, so it applies from the very next transaction. It does not re-run old evaluations.

A pep, pep_rca or sanctioned designation in force also makes the subject’s alerts held, from the moment it is saved: they can’t be closed in bulk, and the AI assistant never calls them a false positive. For a customer, that covers alerts about the accounts they own too.

A subject can have only one active designation of each type. Adding a second pep to someone who is already an active PEP is refused; revoke the old one first if it needs correcting.

On screen or through the API

In the app, open the customer from Customers (or select their name on an alert or case) and use Flag to add a designation, including your own custom: flags and an optional end date, or Remove to revoke one; the Flagged tab of Customers lists everyone with an active flag (step by step: Flagging a customer). The same can be done through the API, as shown below. Sanctions and PEP screening adds designations too: when a reviewer confirms a potential match as a true match, the customer or counterparty gets the designation for that kind of list (Sanctioned for a sanctions list, PEP for a PEP match, and so on) in the reviewer’s name, and a case is opened. A potential match that nobody has confirmed sets no designation. See Reviewing a potential match.

How to add a designation with the API

1. Sign in with curl, as described in Designations API: before you start.

2. Find the customer’s SpeculaPro ID by searching for their reference or name:

   curl -s -b ~/.sp-cookies "$SP/api/v1/customers?q=CUS-004417"

3. Add the designation:

   curl -s -b ~/.sp-cookies -H 'Content-Type: application/json' \
     -d '{"subject_type":"customer","subject_id":"<id from step 2>","type":"pep","pep_class":"domestic",
          "reason":"Deputy Regional Minister since Jan 2025 (Government Gazette, 12 Jan 2025). Checked by E. Owusu, 9 Oct 2026."}' \
     "$SP/api/v1/designations"

   The answer is 201 with the new designation’s id.

4. Check it on the customer’s profile, under designation_history: curl -s -b ~/.sp-cookies "$SP/api/v1/customers/<id>".

The full reference, including every error, is in the Designations API.

Revoking — never deleting

Designations are never deleted. If one no longer applies — a person was wrongly matched, or left office long enough ago — it is revoked, which records who revoked it, when and why. The customer’s profile keeps showing it in the designation history, greyed out and marked removed, with who removed it and why.

To revoke one through the API, send its id and a reason:

curl -s -b ~/.sp-cookies -H 'Content-Type: application/json' \
  -d '{"reason":"Wrong match: different date of birth (1971 vs 1984) and different Ghana Card number. Checked by MLRO."}' \
  "$SP/api/v1/designations/<designation id>/revoke"

This matters because a decision made last year must be explainable using what was true last year. If a designation could simply disappear, nobody could show why a PEP rule fired.

A revocation needs a reason

The database refuses a revocation without a reason. “Duplicate” or “no longer PEP” is not enough for an examiner — say what you checked: “Former District Chief Executive, left office March 2023; three-year post-office period ended; reviewed by MLRO.”

How designations are used

In rules. Rules see the subject’s active designations. The F rules are built around them:

• F1 — any transaction by a sanctioned party is blocked or sent for review;
• F2 — a PEP transaction above a threshold raises an alert;
• F3 — high-risk customers get lower thresholds on every other rule.

In escalation. An escalation policy can apply to cases whose subject has a designation, so that, for example, PEP cases open at level 2 in a named team’s queue. The ready-made choices cover pep and pep_rca, sanctioned, and high-risk customers (high_risk, or a high risk rating); a condition of your own can test any designation. The policy looks at the subject’s designations when the case is opened: a case already open when the designation is added keeps its route, so escalate it by hand. See Escalation policies.

Designations and risk rating

Separately, every customer has an overall risk rating: unrated, low, medium, high or unacceptable. The rating usually comes from your onboarding risk assessment and is sent to SpeculaPro with the customer record. A designation is one specific reason for concern; the rating is your overall judgement. Rules can use either.

Related

• Designations API
• Customers API
• F. Customer risk and designations
• Escalation and SLAs
• Lists
• Sanctions and PEP screening