How a Billion-Dollar PEP Passed the System

What Isabel dos Santos Taught Us About Sanctions Screening

Isabel dos Santos wasn’t flying under the radar. She was flagged as a politically exposed person (PEP). She was publicly known. And yet, over decades, she transformed public resources into private assets—appropriating state oil, telecom, and diamond interests into a personal empire worth billions.

This wasn’t savvy entrepreneurship. It was state-enabled extraction, dressed in designer branding and legitimised by the world's most prestigious firms.

The problem wasn’t a lack of data. It was a lack of consequence.

Who Is Isabel dos Santos?

Born in 1973, Isabel dos Santos is the eldest daughter of José Eduardo dos Santos, Angola’s former president who ruled the country for nearly four decades—from 1979 to 2017. While Angola endured a devastating civil war and widespread poverty, Isabel quietly became Africa’s first female billionaire.

She held stakes in oil, diamonds, telecoms, banking, and construction. Her empire stretched across Angola, Portugal, and offshore jurisdictions. In 2020, the Luanda Leaks—an investigation by the International Consortium of Investigative Journalists—revealed how this wealth was amassed: through preferential deals, public contracts, and state assets transferred under her father’s watch.

Western banks, consulting firms, and auditors helped her build and protect this fortune. And while 68% of Angolans lived on less than $2 a day, Isabel’s lifestyle included private jets, luxury penthouses, and waterfront villas in Dubai.

She was eventually sanctioned by Angola, the US, UK, and Portugal. But by then, the damage had already been done.

What Is Sanctions Screening Actually Meant to Do?

Sanctions screening is designed to stop dangerous or high-risk individuals and entities from accessing the financial system. It’s not just for corrupt officials. The names on these lists include:

• Terrorist groups and their financiers

• Illegal arms dealers and trafficking networks

• Politicians and military figures accused of war crimes

• Rogue states engaging in aggression or repression—like Russia, now the most heavily sanctioned country in the world

These lists are maintained by international and national bodies—OFAC (US), the United Nations, the EU, the UK, and others. Some are targeted (e.g. individuals), others are sweeping (whole sectors or regions).

PEP screening is different but related—it flags high-risk individuals based on their political exposure, requiring enhanced scrutiny, not outright prohibition.

Dos Santos was the daughter of Angola’s president, and at one point the richest woman in Africa. Her name was in databases. Her family ties were not a secret. Yet the system treated her not as a red flag but as a client.

Why the System Failed—and Still Does

Even with accurate lists, screening only works if it leads to action. That’s where the system broke down for Angola.

Major firms assessed Isabel’s risk. And then onboarded her anyway.
Some banks stepped away. Others stayed. And some prestigious global consultants and accountancy firms enabled her to scale, structure, and protect the very assets now under investigation.

This wasn’t a blind spot. It was a decision.

Compliance, in these cases, wasn’t about prevention. It was about plausible deniability.

Respectability Laundering Is the Real Business Model

Sanctions risks don’t always start in the shadows. Often, they start with respected professionals giving cover to disreputable flows.

• PwC served as her accountant, tax adviser, and consultant

• McKinsey and Boston Consulting Group worked with her companies

• Corporate law firms built the offshore structures

These firms weren’t tricked. They were incentivised.

"Without the assistance of these people, these corruption schemes and the money laundering that flows from that would be unable to happen," said Transparency International’s UK office.

If screening is seen as a formality rather than a firewall, this cycle repeats.

Who’s Left Holding the Risk?

Here’s the paradox: the financial institutions most exposed to risk are often the least equipped to manage it.

Across Africa, South Asia, and South East Asia emerging markets, smaller banks, fintechs, microfinance providers and cooperatives operate in high-risk environments with minimal compliance infrastructure. They face increasing pressure to implement sanctions screening, without the resources of multinational firms.

That’s where Anqa comes in.

We build accessible, affordable screening tools for institutions that can’t afford to wait for enforcement.

• Real-time access to global sanctions lists

• Simple interfaces designed for real-world workflows

• Pay-as-you-go pricing that doesn’t punish smaller players

Because stopping illicit finance shouldn’t require a Big Four budget.

Final Thought

When Isabel dos Santos was finally sanctioned, the world acted surprised. But the signs were there for years. Publicly. Repeatedly. Systematically ignored.

Sanctions screening isn’t just about having a list. It’s about using it.

The global compliance infrastructure failed Angola. But it doesn’t have to keep failing.

For the full investigative story behind Isabel dos Santos, PEPs, and the cost of inaction:
The Princess and the PEP: A Sanctions Screening Fairy Tale
By Anqa co-founder, Justin Pemberton