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What is a Politically Exposed Person (PEP)?

COMpLIAnCE SOLutIOnSPowered by Bankers Almanac

test yourselF: ArE thEy PEPs?

A politically exposed person does not always mean an individual who directly holds public office, it also includes their immediate family members, close business associates, as well as any senior executives of state owned enterprises.

Although there is no Fixed or deFinitive

criteriA For A PeP, it is usuAlly dEfinEd As:

Legislative Body Members of Parliament

Armed forces high-ranking officers

state-OwnedEnterprises senior executives

Central financialinstitutions courts of Auditors

Boards of central Banks

immediate familyMembers Parents and children siblings spouse/Partner in-laws uncles and Aunts

Known CloseAssociates close business relations or joint beneficial ownership of legal entities or legal arrangements with a PeP

sole beneficial ownership of legal entity which is known to have been set up for benefit de facto of the PeP

diplomatic Body Ambassadors

chargés d´Affaires

international sports Committee Members

Executive Body heads of state

Ministers of deputy heads of government

Assistant Ministers

Judiciary Body supreme courts

constitutional courts

high level Judicial Bodies

Mayor of Paris

Perhaps. international definitions usually vary, however

with new FAtF recommendations, this person may

soon be considered a PeP on a local level.

An actress

no. Although a person of an influence, under

international definitions actresses are not considered

PePs, but prominent individuals.

organizations need to understand their local regulator’s definition and

their own risk exposure to better assess who should be a PeP and who

is not a PeP, even though they may or may not public hold office. it is

the responsibility of the compliance department to exercise proper due

diligence and undertake a risk-based approach in determining the true

nature of the client base, even for seemingly low-risk lines of business.

it can be a challenge to identify these risks associated with your client

relationships and they are often not so apparent. trust your intelligence

in Accuity’s global PeP database powered by Worldcompliance®, a

lexisnexis company to help you properly assess your exposure and

protect your reputation.

A former member of the board of directors for a state owned enterprise

Varies. senior staff of state owned enterprise are PePs

in their own right under the international policies, but

determining when a PeP is no longer a PeP can vary

between countries and organizations. Former Member of

the board of directors man still have powers to influence,

which may make them more prone to corruption.

head of Olympic Committee

yes. the new FAtF recommendation expanded the

def to include individuals of high status in international

sports committees.

EU 3rd AML directive - http://eur-lex.europa.eu/LexUriServ/LexUriServ.do?uri=CELEX:32005L0060:en:NOT FATF-GAFI - http://www.fatf-gafi.org/pages/glossary/n-r/