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Politically Exposed Person (PEP)
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Updated on:
July 19, 2023

Politically Exposed Person (PEP)

An individual who is or has been entrusted with a prominent public function. Due to their position and influence, it is recognised that many PEPs are in positions that potentially can be abused for the purpose of committing money laundering (ML) offences and related predicate offences, including corruption and bribery, as well as conducting activity related to terrorist financing (TF).

  • PEPs include current or former senior political figures, their family members, and close associates.
  • Financial institutions must perform enhanced due diligence (EDD) on PEPs due to higher risk profiles.
  • PEP status does not necessarily imply wrongdoing, but demands increased scrutiny and monitoring.
  • Identification of PEPs and monitoring transactions are vital components of anti-money laundering (AML) and compliance efforts.

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A Politically Exposed Person (PEP) is an individual who holds, or has held, an influential public office or position that may increase their vulnerability to bribery, corruption, or money laundering. In the context of corporate and commercial financial services, the identification and management of PEPs are essential components of a robust compliance programme, as well as adherence to anti-money laundering (AML) regulations.


PEPs can be categorised into foreign, domestic, and international organisation PEPs. Foreign PEPs are individuals who hold or have held significant public positions in foreign countries, such as heads of state, high-ranking government officials, or senior executives of state-owned corporations. Domestic PEPs hold or have held similar positions within their own country. International organisation PEPs are persons who hold or have held senior positions in international organisations, such as the United Nations or the European Union.


Financial institutions are required to perform enhanced due diligence (EDD) on PEPs, their family members, and close associates, given their heightened risk profiles. This entails obtaining additional information on the PEP's source of wealth, the purpose of the business relationship, and ongoing monitoring of transactions. It is crucial to note that being classified as a PEP does not automatically imply any wrongdoing; rather, it necessitates increased scrutiny to ensure compliance with regulatory requirements and minimise exposure to financial crime risks.


Incorporating technological advancements, PEP checks can be automated using specialised software solutions to streamline the due diligence process and ensure compliance with regulatory requirements. These software solutions harness the power of artificial intelligence, machine learning algorithms, and vast databases of PEPs, sanctions lists, and adverse media information. By automating PEP identification and monitoring, financial institutions can significantly reduce the time and effort required to conduct manual checks, minimise human error, and enhance the accuracy and efficiency of their compliance programmes.


Automated PEP screening tools enable financial institutions to regularly scan their customer databases, flagging any existing or newly added clients who may be classified as PEPs. These tools can also identify changes in a client's PEP status, monitor transactions for suspicious activity, and generate alerts for further investigation. Additionally, the software can assist in maintaining a comprehensive audit trail of PEP checks and actions taken, ensuring that financial institutions can demonstrate compliance with AML regulations to regulators and auditors.


By integrating automated PEP checks into their compliance processes, corporate and commercial financial services organisations can significantly improve their ability to identify and manage risks associated with Politically Exposed Persons, ensuring adherence to regulatory requirements and reinforcing their commitment to combating financial crime.


In summary, a Politically Exposed Person is an individual with a significant public position, which increases their susceptibility to corruption and money laundering risks. Financial institutions must conduct enhanced due diligence for PEPs, their families, and associates to maintain compliance with AML regulations and mitigate potential risks.


PEP and Sanction data is available within FullCircl's company lifecycle intelligence platform.

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