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Politically Exposed Person Definition

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PEPs definitions

The following Politically Exposed Person definitions are based on the latest FATF guidelines, published in 2013. These definitions do vary by jurisdiction, however, so they should be used with caution.

Domestic Politically Exposed Person Definition

Individuals who are, or have been, entrusted with prominent public functions domestically. Examples include heads of state or of government, senior politicians, senior officials in the government, judiciary, or military, senior executives of state owned corporations, and important political party officials.

Foreign PEPs

The foreign politically exposed person definition is individuals who are, or have been, entrusted with prominent public functions by a foreign country. Examples include heads of state or government, senior politicians, senior officials in the government, judiciary, or military, senior executives of state owned corporations, and important political party officials.

International organization politically exposed person definition

Individuals who are, or have been, entrusted with a prominent function by an international organisation. The categorization applies only to members of senior management or people entrusted with equivalent functions, i.e. directors, deputy directors and members of the board or equivalent functions. These are also known as Heads of International Organisations or (HIOs).

PEPs by relation

Individuals whose link to a “direct” PEP means that they are themselves classed as a PEP. Examples include family members (consanguine or through marriage and other forms of partnership) and close associates (social or professional). These can also be known by the acronym RCA (Relatives and Close Associates).

Foreign vs. domestic PEPs

The difference between a foreign PEP and a domestic politically exposed person definition is the country which has entrusted the individual with the prominent public function. Other factors, such as country of domicile or nationality, are not relevant in determining the type of PEP, but may be relevant in determining the risk level of a specific domestic PEP (foreign PEPs are always high risk). It should also be noted that a domestic PEP is subject to the foreign PEPs requirements if that individual is also a foreign PEP through another prominent public function in another country.

Government-issued PEP lists

Countries sometimes publish lists of domestic PEPs or prominent public functions. This is not required by the FATF standards, however, and such lists have potential shortcomings and might pose challenges for effective implementation.

Countries might publish two types of list: (1) a list of positions/functions that would be held by a PEP, or (2) a list of names of PEPs. In general, while inclusion on a list can confirm that a person is a PEP, not being featured on a list does not exclude the possibility that a person is a PEP.

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Disclaimer: This is for general information only. The information presented does not constitute legal advice. ComplyAdvantage accepts no responsibility for any information contained herein and disclaims and excludes any liability in respect of the contents or for action taken based on this information.

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