PEPs

Politically Exposed Person (PEP)

A Politically Exposed Person (PEP) or someone holding a public office role is defined as:

  • • Heads of State, heads of government, ministers and deputy or assistant ministers;
  • • Members of parliaments or of similar legislative bodies;
  • • Members of supreme courts, of constitutional courts or of other high-level judicial bodies the decisions of which are not subject to further appeal, except in exceptional circumstances;
  • • Members of courts of auditors or of the boards of central banks;
  • • Ambassadors, charges d’affaires and high-ranking officers in the armed forces (other than in respect of relevant positions at Community and international level);
  • • Members of the administrative, management or supervisory boards of State-owned enterprises; and
  • • Directors, deputy directors and members of the board or equivalent function of an international organisation.

Or, an immediate family member of an individual entrusted with a prominent public function (as per the definition above), such as:

  • • A partner, that is someone considered by his or her national law as equivalent or broadly equivalent to a spouse;
  • • Children and their spouses or partner;
  • • Parents;
  • • Grandparents and grandchildren; or
  • • Siblings.

Or, a person who is or has been entrusted with a prominent function by an international organisation referred to as members of senior management, e.g:

  • • Directors;
  • • Deputy directors;
  • • Members of the board or equivalent functions;

Or, a close associate of an individual entrusted with a prominent public function, including any person who is known to:

  • • Maintain a close business relationship with such a person, including a person who is in a position to conduct substantial financial transactions on behalf of the PEP.

Examples of a close associate include the following types of relationships:

  • • Known ‘partners’ outside of the family unit e.g. girlfriends, boyfriends, mistresses of the PEP. Consideration should be given to the social, economic and cultural factors when determining how close the relationships are.
  • • Prominent members of the same political party, civil organisation, employment connections to the PEP.
  • • Business Partners or associates, especially those that share (beneficial) ownership of legal rights with the PEP, or sit on the same Company Board as the PEP.
  • • Consultants/advisers to the PEP
  • • PEP supported charities and none-profit making organisations