DOCUMENT & DATA MANAGEMENT
KNOWLEDGE & EXPERIENCE
A politically exposed person (PEP) is an individual who is or has been entrusted with a prominent function.
Bitwire use the Financial Action Task Force (FATF) definition of PEP and PEP Categorisation. FATFis an inter-governmental body established in 1989 by the Ministers of its Member jurisdictions. The FATF currently comprises 34 member jurisdictions and 2 regional organisations, representing most major financial centres in all parts of the globe. The objectives of the FATF are to set standards and promote effective implementation of legal, regulatory and operational measures for combating money laundering, terrorist financing and other related threats to the integrity of the international financial system.
Due to the risks associated with PEPs, the FATF Recommendations require the application of additional AML/CFT measures to business relationships with PEPs. These requirements are preventive (not criminal) in nature, and should not be interpreted as meaning that all PEPs are involved in criminal activity.
Heads of state and government
Members of government (national and regional)
Members of Parliaments (national and regional)
Heads of military, judiciary, law enforcement and board of central banks
Top ranking officials of political parties
Senior management and board of directors of state owned businesses and organisations
Senior officials of the military, judiciary, and law enforcement agencies
Senior officials of other state agencies and bodies and high ranking civil servants
Senior members of religious groups Ambassadors, consuls, high commissioners
Mayors and members of local county, city and district assemblies
Senior officials and functionaries of international or supranational organisations
Siblings and in some jurisdictions may also include grandparents, grand children, other bloodrelatives and relatives by marriage (ranked at one level down from the level the PEP associated with is ranked unless the family member in question is a PEP on his/her own rightin which case, the position thus held will determine the risk ranking of that individual)
Any natural person who is known to have joint (or sole) beneficial ownership of legal entitiesor legal arrangements which is known to have been set up for the benefit of a person who is a PEP, or any other close business relations with a person who is a PEP.
Close business colleagues and personal advisors/consultants to the politically exposed person as well as persons who obviously benefit significantly from being close to such a person (ranked at the same level as the PEP associated with but not higher unless the business associate in question is a PEP on his/her own right in which case, the position thus held will determine the risk ranking of the business associate)
Business associates who are not PEPs on their own right but who share a common platform at a board level in non-SOEs whether privately held or not (ranked at one level down from the level the PEP associated with is ranked)
Businesses which are 51%-100% state owned
Subsidiaries of high risk and medium to high risk businesses as long as these subsidiaries also fit the criteria defined therein relating to the ownership structure and representation on the board
Companies in which % of government control is not defined but there is evidence of state ownership and the government is involved in the company through its representation on the board
</=50% state owned and where government is represented on the company’s board
State owned/controlled companies at local or municipal government level regardless of % of ownership as long as government is represented on the company’s board