In basic terms we can
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Table of Contents
PEPs in Government Roles
- Legislative Bodies: A good example here would be a Member of Parliament
- Executive Bodies: A PEP could range from the head of state down to the assistant ministers
- Diplomatic Roles: Ambassadors or charges d’affaires would be considered PEPs
- Judiciary Bodies: Key people working within supreme courts, constitutional courts or high-level judicial bodies
- State-Owned Enterprises: A PEP would typically be anyone from a senior executive upwards. However, even former members of the board of directors no longer associated with an organisation may retain influence and still be flagged as PEPs
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PEPs in Organisations and Institutions
- Central Financial Institutions: Examples here would be the Court of Auditors and members on the boards of central banks
- Armed Forces: In this situation a PEP rating would typically only apply to a high-ranking officer
- International Sports Committees: Members of these committees may be influenced to vote on the location of major sporting events/contracts for building venues, etc., so have recently been included by FATF under their definition of a PEP
Known ‘Close Associates’ who are Considered PEPs
- Anyone who has a close business relationship or joint beneficial ownership of legal entities or legal arrangements with a PEP
- Anyone who has the sole beneficial ownership of a legal entity which is known to have been set up for the benefit de facto of the PEP
Immediate Family Members who are Considered PEPs
- Parents and children of PEPs
- Spouse or partner
- Siblings
- Uncles and aunts
- Even slightly indirect family members (such as in-laws) will be considered as a politically exposed person
Note: Each country may have different local PEP regulations that you need to comply with when doing business in that region.
Accuity has produced a handy infographic that summarises information on who should be classified as a Politically Exposed Person.