What is Politically Exposed Person (PEP)?

Meaning of a Politically Exposed Person (PEP) is a person who is prone to engage in bribery or corruption due to their prominent position or influence.  The potential risk of using titles for criminal activity makes them high-risk individuals. Among PEPs, there are different levels in terms of risk levels. For instance, foreign PEPs generally have higher risks than domestic PEPs.

Classifying a potential client as a PEP doesn't mean a corporation can't work with them. PEP check is only part of the process that allows financial institutions to conduct a complete risk assessment, and awareness of red flags is essential in this assessment. Sometimes, matching just one of these politically exposed person indicators might be linked with financial abuse.

Financial institutions frequently employ advanced AML compliance software to strengthen their risk assessment processes, which not only streamlines the identification and assessment of PEP-related risks but also enhances the efficiency of PEP screening, enabling institutions to address potential vulnerabilities and proactively maintain regulatory compliance.

What is PEP According to FATF?

There are several criteria to decide who is a PEP person according to the FATF's definition;
  • In governmental bodies: A senior government official in the legislative, judiciary, or executive bodies and diplomatic roles who has a prominent public function. Examples of politically exposed persons in governmental bodies, parliament members, ambassadors, or judges in the supreme court
  • In organizations: A senior executive of a government-owned commercial enterprise or senior official of a major political party. For instance, board members in a central bank, party presidents, or high-ranking soldiers
  • Associates: Close associates who are closely connected to a PEP, socially or professionally. For instance, family members and close relatives of parliament members, someone with the beneficial owner of a legal entity or a company in which the government is the sole or majority shareholder. 

Who is Considered a Politically Exposed Person?

Types of Politically Exposed Persons

According to FATF, there are six main types of PEPs: Foreign, Domestic, International Organizations, Family Members, Close Associates, and National PEPs.

Foreign PEPsProminent individuals holding political positions in other countries, including heads of state, government ministers, diplomats, and high-ranking military officers.
Domestic PEPsSignificant political figures within their own country, such as heads of state, government ministers, members of parliament, and senior government officials.
Family Members of PEPsClose relatives of PEPs, like spouses, children, and siblings, may be susceptible to engaging in corrupt or money laundering activities on behalf of the politically exposed individual.
Close Associates of PEPsPeople closely linked to PEPs, including business associates, advisors, or personal friends, may be at risk of engaging in illicit activities due to their proximity to influential figures.
International Organization PEPsOfficials working in international organizations, such as the United Nations or the European Union, are subject to exposure to corruption and money laundering risks.
National PEPsNotable political figures within their own country, which can include regional or local government officials, mayors, and other influential figures, even if they lack international prominence.

Examples of Politically Exposed Persons

To clarify who qualifies as a PEP and who doesn't, let’s examine various examples and their qualifications:

  • Can mayors be labeled as PEPs? Yes, since they possess significant control over urban administrations, they have the capability to influence or fall victim to fiscal wrongdoings.
  • Do celebrities meet the criteria for being classified as PEPs? Typically, they do not. Although possessing wealth and social influence, celebrities lack the authority over the essential systems of governance, finance, law enforcement, or the military that would categorize them as PEPs.
  • Are judges considered to be PEPs? Indeed, they are. Given their role in the interpretation and application of the law, judges are exposed to potential financial influences that could sway legal interpretations.
  • Could being a family member make one a PEP? This hinges on the nature of their relationship to an established PEP. If strong social, business, or legal connections to a PEP are present, then they might also be regarded as PEPs. In the absence of such ties, they likely would not be.

PEP Risk Levels Based on FATF Guidelines of Red Flags

Every regulated corporation must follow the guidelines when working with a PEP. After the client is uncovered as a PEP, corporations are responsible for the ongoing due diligence checking process. FATF recommendations include four levels of risk for PEPs because some have a higher risk, whereas others have a lower risk. The categories are listed as follows;

Low-level risk includes;
  • Supranational or international business officials, senior functionaries.
  • Mayors and local, state district, and urban assembly members.  
Medium/Low-level risk includes the governmental board and top-ranking officials of state-owned organizations and businesses. For example;
  • Head officials of judiciaries, banks, military, law enforcement
  • Senior members of state agencies
  • High-ranked civil servants and religious organizations
  • Commissioners
  • Consuls
  • Ambassadors
High-level risk includes;
  • Heads and government members
  • Parliament members
  • Head officials of judiciaries, banks, law enforcement, military, and religious organizations are also publicly exposed.
  • Prominent political party members.
Master worldwide PEP screening compliance with expert insights on AML practices, regulatory standards, and risk management in our definitive guide.

What are the Red Flags for FATF?

The Financial Action Task Force (FATF) has introduced red flags of PEP to help corporations detect illegal activities. Several of these indicators should raise some suspicions based on their information matching. In some cases, it might even lead to PEP money laundering. Additionally, a particular nation or state may also have indicators for suspicion that must be considered crucial.
According to the FATF, the measures that will enable companies to detect and control these people are listed as follows, and these can help to decide red flags for PEPs:

Identity Shielding: As PEPs are aware of their pep status, sometimes they try to hide their identity or avoid being in the spotlight. For example:
  • Assigning legal ownership to somebody
  • Abnormally or constantly interacting with intermediaries
  • Using corporate vehicles without valid business reasons or for confusing involved ownership and industries

To streamline the implementation of these measures and enhance the detection of PEP-related risks, financial institutions often leverage advanced AML compliance software. This technology facilitates the systematic identification of red flags, aiding corporations in effectively managing the complexities associated with PEPs' potential involvement in illicit activities.

Suspicious Behavior:
  • Being secretive or uncomfortable about the source of funds and wealth
  • Providing false, inaccurate, or insufficient information
  • The information doesn't match with publicly available data
  • Eagerness to explain the reason behind their business in the country's DNFBP or financial institution
  • PEP has been denied an entry visa
  • Funds belonging to PEP move from one country to another
  • A steady flow of wire transfers or cash-out
  • No credible explanations or details for certain business relationships, transactions
Position in the Company:
  • Access, authority, and control over the corporation's funds, operations, and policies
  • Informal/formal ability to control mechanisms against TF/ML
  • Influence/control over government or corporate accounts
  • Having authority or ownership over DNFBP for financial institutions.

Learn more about jurisdiction-based pep regulations

The Industry: 

  • Banking and Finance
  • Military and defense
  • Businesses that work with the government or state agencies
  • Construction, mining, and extraction
  • Public goods provision
  • The account shows ongoing activity in a short period after a long period
  • Private banking demands
  • Wire transfers without economic explanation or lacking beneficiary information
  • Anonymous payments or transactions received from an unknown third party
  • Funds are moved constantly from one account to another or between financial institutions without a business rationale
  • Steady cashflows, massive global funds transfers, or wire transfers
  • Having and using multiple bank accounts without an apparent reason
Services and Products:
  • Businesses are catering to foreign clients
  • Service and trust providers
  • Concentration/correspondent accounts
  • Real estate
  • Dealers in high-value transport vehicles like ships, sports cars, planes, and helicopters
  • Dealers' invaluable stones, metals, and luxury goods
Local Indicators: These are considered high-risk based on geographic risk factors.
  • Domestic or foreign high-risk country.
  • A country with a high risk of corruption.
  • Countries with mono-economies.
  • A country that did not sign a relevant anti-corruption convention like the OECD Anti-Bribery Convention and the UNCAC.

How Long is a PEP Considered a PEP?

According to Recommendation 12 from the FATF guidelines, the duration for which an individual is considered a PEP does not have a fixed time limit. Instead, the approach towards a client who has ceased to hold a prominent public role should be risk-based rather than adhering to a strict timeline.

This implies that the classification of someone as a PEP can extend beyond their tenure in a high-profile position, especially if they maintain a significant level of influence or recognition in their area of expertise. Identifying whether someone is a current or former PEP is the first step, and how to manage this relationship is up to your judgment. Continuous and careful monitoring is key to effectively managing any associated risks.

PEPs are at reduced risk when they leave their duties, while the risk always remains for companies.

Changes in PEP Status

Over the years, several changes have occurred to the PEP status and how governments and financial institutions worldwide perceive it. 

Changes in PEP Meaning 

One of the most notable changes in the PEP status is the way in which it is now defined. Initially, the term was used to describe only senior government officials and their immediate family members. However, this definition has since been expanded to include individuals who hold prominent positions in international organizations and their close associates. 

Changes in PEP Monitoring

Another significant change in the PEP status is the way in which it is now being monitored. Previously, governments and financial institutions relied primarily on PEPs' self-disclosure to identify their status. However, this approach was often ineffective, as some PEPs may have chosen to hide their status or failed to disclose it accurately. Today, governments and financial institutions have access to sophisticated databases and PEP screening tools that allow them to identify PEPs more accurately, thanks to advanced AML compliance software.

Changes in Treatments for PEP 

There has been a shift in how governments and financial institutions treat Politically Exposed Persons. Previously, PEP lists were often viewed as including high-risk customers who needed to be closely monitored to ensure that they were not involved in illegal activities. However, this approach has shifted in recent years, with many governments and financial institutions recognizing the valuable role that PEPs can play in promoting economic growth and development. Today, many financial institutions offer specialized services and products designed to meet the unique needs of PEPs, such as enhanced due diligence and risk management tools. 

However, one thing is clear: the Pep status will continue to play a critical role in the fight against money laundering and corruption, ensuring that individuals with power and influence are held accountable for their actions.

How to Identify PEPs?

Identifying PEPs is crucial for financial institutions to prevent money laundering. The process involves:

  1. Identity Verification: Using government-issued documents to confirm an individual's identity.
  2. Ownership Investigation: Analyzing a company's ownership to detect any PEP involvement.
  3. PEP Screening: Utilizing PEP databases and reliable data sources, including government and international organization registers, to identify PEPs effectively.

These steps ensure thorough customer due diligence (CDD), safeguarding against financial crimes.

Why is PEP Screening Important?

Financial crimes are a serious concern worldwide, and firms must comply with anti-money laundering regulations to combat such crimes. As a part of this compliance, institutions must identify customers who may have a higher risk of being involved in financial crimes, which is why PEP screening is necessary during the account opening process. Failure to follow PEP screening procedures can result in penalties from AML regulators for non-compliant organizations.

Optimize Your PEP Screening with These Key Strategies

To maintain compliance and manage risks effectively, businesses must prioritize an efficient screening process for PEP. Here's a concise guide to enhancing your PEP checks:

  1. Start with a solid AML screening framework to identify PEP risks accurately.
  2. Customize your screening efforts based on the level of risk, ensuring a targeted and efficient process.
  3. Keep your PEP lists and records up-to-date to capture the most current information, enhancing the accuracy of your screenings.
  4. Utilize advanced, automated solutions for faster and more reliable PEP checks.
  5. Continuously monitor for changes in regulations and report any suspicious activities promptly.

Adhering to these strategies will streamline your PEP screening process, ensuring compliance and protecting your business from potential risks.

Sanction Scanner provides solutions that are compatible with global and local AML regulations. You can check our products for SanctionsPEP lists, and Adverse Media Screening to protect your company from criminal activities.

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