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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/