PEP: Politically Exposed Persons

When working with PEPs you need to be particularly careful.
Detect cover-ups in order to identify links.

Identifying cover-ups: What are PEPs?

Politically exposed persons (PEPs) pose a particularly high risk if you are involved in a business relationship with them. PEPs are Individuals who hold or have held important public office in the past. Before entering into a business relationship with prominent PEP individuals or through organizations as customers or suppliers, running them through a PEP list and doing thorough due diligence on them would reveal any financial crimes they may be associated to avoid issues in the future.

Click here for a summary of the various categories.

The EU Anti-Money Laundering Directives define a PEP as any holder of a public office at home or in a foreign country. According to the AMLDs, natural persons are those who have been assigned with prominent political functions and immediate family members are known to be close associates of such persons.

PEPs natural person may include:

Legislative bodies

Political institution which holds the legislative power in a state, and often controls the executive power.

Executive bodies

A part of the government with authority and responsibility that enforces the law for the daily administration of the state.

Security forces

These are statutory organisations with an internal security commission tasked with the provision of public security

Judicial bodies

Any public organization or branch of government that enforces the law and responsible for the administration of justice.


A bureaucrat within an institution of government can compose the administration of any organization of any size.

Relatives of Politicians

Parents, children, siblings, in-laws, etc are considered as relatives of politicians.

Types of Politically Exposed Person (PEP)

It is important to understand what type of politically exposed person you are screening, as this will help you better understand the risk that they may pose.

The Anti-Money Laundering and Counter-Terrorism Financing Act 2006 (AML/CTF Act) identifies three types of PEPs:

  • Domestic politically exposed person - entrusted with a prominent public role in a national government.
  • Foreign politically exposed person - a high ranking political figure in a foreign country.
  • International organisation politically exposed person - prominent public members of an international organisation, such as the UN, WTO or NATO.

Examples of PEPs

Examples of politically exposed persons include:

  • Heads of government or heads of state
  • Senior politicians and government officials
  • Top military or judicial officials
  • Senior executives of government owned organisations
  • High ranking political party members

Close associates such as immediate family members and support staff are also considered PEPs.

Why are PEPs particularly risky?

Because of their influential public position, politically exposed persons are assumed to be at greater risk of corruption and money laundering. PEPs are not infrequently found to be involved in the payment of bribes to influence decisions on the awarding of contracts, finance terrorism, evade tax or launder illegally obtained money.

For example, the Panama Papers published in 2016 revealed details of 140 PEPs who had used letterbox companies to launder money or disguise their ownership of dirty money.

Be on the alert: Doing Due Diligence on PEPs

PEPs call for enhanced due diligence, governance risk and compliance checks under Section 6 of the German Money Laundering Act (GWG). Among other things, the checks must clarify the origin of assets in order to prevent money laundering. In a risk-based approach, PEPs are automatically classed as high risk. A robust PEP check uses PEP lists of politically exposed persons. The regulatory authority or financial regulators established by the government is responsible for providing guidance, assessing and enforcing compliance with PEP standards to banks. Banks may oversee enhanced due diligence measures or legal action task based on the risk assessment. This may require intensive due diligence for higher-risk customers, especially those for whom the sources of funds are not clear.

In many organizations there is a widespread but mistaken idea that because you have worked with your business partners for many years, you know them sufficiently well and therefore do not need to perform a thorough risk and compliance check. This insight is usually lacking if you go further along the supply chain and realize that it affects the beneficial owner. This means that it is essential to check suppliers and also their suppliers against PEP lists to see if someone is a political figure.

With regard to holders of public office at sub-national level, PEP checks are usually regarded as unnecessary unless the person’s political importance is similar to that of a person in a similar public position at national level. In addition, KYC PEP checks are not necessary for business relationships that involve only occasional or very small financial transactions.

Nexis Diligence+ is a web-based third party risk and compliance check tool for conducting due diligence. This due diligence software aggregates PEPs data from multiple sources database to enable thorough checks of politically exposed persons or political figures.

A Search & Retrieve API enables ongoing monitoring of specific records, such as PEP and watchlists, for integration with in-house systems for proactive risk management and anti-money laundering (AML) checks.

What risks do organizations face if their PEP due diligence is insufficiently thorough?

Organizations that fail to check their business partners sufficiently thoroughly can expect not only reputational damage but also fines of an unlimited amount to stay safe from this avail Anti-money laundering services (AML) For example, in 2015 a bank was fined 72 million pounds sterling because the required PEP checks had not been performed.

Guidelines on managing PEP risks

Our guidelines summarize the most important information on politically exposed persons. Read about issues including the risks of working with PEPs, where the PEP risk is greatest and how organizations can avoid PEP risks.

Frequently Asked Questions

Answers to some popular questions

Why are PEPs particularly risky?

Politically exposed persons are assumed to be at greater risk of corruption and money laundering because of their influential position. 

Who is classed as politically exposed?

Who is classed as politically exposed?

What is a politically exposed domestic person?

People who hold position in domestic public offices, like Heads of State Government, judicial or military officials, senior officials of state owned corporations, important political party officials.

Is a mayor a politically exposed person?

It would depend on who is the observer. Mayor of California is a domestic PEP for an American bank but a foreign PEP for its European counterpart.

How long is a person considered a PEP?

A Politically exposed person is continued to be considered a PEP for a period of at least 12 months from the day he/she leaves the public office position.

What is PEP and sanction list screening?

Politically Exposed Persons and Sanctions screening allows for companies to avoid regulatory and reputational risks by identifying sanctioned companies and the risks involved allowing to mitigate them.

Disclaimer: The information provided is based on regulatory guidance and best practices recommendations. It is for educational purposes only and should not be construed as legal advice or a definition of the PEPs data covered within our solutions.

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