politically exposed Person

In financial regulation, a politically exposed person (PEP) is one who has been entrusted with a prominent public function. A PEP generally presents a higher risk for potential involvement in bribery and corruption by virtue of their position and the influence that they may hold. The term "PEP" is typically used to refer to customers in the financial services industry, while "foreign official" refers to the risks of third-party relationships in all industries.

Definition by the Financial Action Task Force on Money Laundering

While there is no global definition of a PEP, most countries have based their definition on the 2003 Financial Action Task Force on Money Laundering (FATF). FATF is an international inter-governmental body, founded in 1989 on the initiative of the G7 and hosted by the OECD, to set standards and promote implementing measures against money laundering, financing of terrorism and financing of proliferation of weapons of mass destruction to preserve the integrity of the global financial system.

In February 2012, the FATF's latest definition of politically exposed persons (PEP), revised from 2003, is as follows :

• Foreign PEPs : individuals who are or have been entrusted with prominent public functions by a foreign country, for example Heads of state or Heads of government, senior politicians, senior government, judicial or military officials, senior executives of state owned corporations, important political party officials.

• Domestic PEPs : individuals who are or have been entrusted domestically with prominent public functions, for example Heads of State or of government, senior politicians, members of parliament, senior government, judicial or military officials, senior executives of state owned corporations, important political party officials. (Not all countries subscribe to the concept of domestic PEPs with respect to regulatory requirements/application of due diligence. For example, US law, specifically Section 312 of the USA Patriot Act and its implementing regulations provide for enhanced due diligence for SFPFs (Senior Foreign Political Figure) only, defined as: "a current or former senior official in the executive, legislative, administrative, military, or judicial branches of a 'foreign' government...a senior official of a major 'foreign' political party; and a senior executive of a 'foreign' government-owned commercial enterprise.)

• Persons who are or have been entrusted with a prominent function by a state owned enterprise or an international organization refers to members of senior management, i.e. directors, deputy directors and members of the board or equivalent functions.

Requirements for a PEP apply to family members or close associates, any individual publicly known, or known by the financial institution to be a close personal or professional associate.

A forerunner definition was by the 1997 OECD Anti-Bribery Convention aimed at reducing corruption in developing countries, which came into force February 1999; it used the term 'foreign official'.

Implementation

Most of the 37 FATF member countries treat domestic and foreign PEPs with heightened scrutiny. The FATF guidance implies that if a person is a foreign PEP, it de facto makes them a domestic PEP in their own country. This makes sense for crime prevention, because to export proceeds of crime, the PEP must first use their own domestic financial system and thus, importance is placed on domestic, and non-foreign PEPs.

Risk screening

Most financial institutions view a PEP as a potential compliance risk, and perform enhanced monitoring of accounts that fall within this category. Screening for PEPs is usually performed at the beginning of account opening, called standard due diligence or know your customer (KYC). Screening of accounts periodically is performed as part of ongoing due diligence.