OFAC has nothing to do with PEP's. Assuming that your customer, PEP or not, isn't on the SDN List, OFAC could care less how you handle the situation. That aside, your overall BSA Compliance program should have a procedure in place to determine if this individual is actually a PEP and you should respond accordingly.
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"100 victories in 100 battles isnt the most skillful. Subduing the other's military w/o battle is the most skillful." Sun-Tzu