Chapter 3 - PEPs

Question 1

Who does the PEP label extend to?

Answer 1

The families and close associates of current or former high political figures or those who hold (or have held) public office.

Question 2

What is the definition of a PEP according to the UN?

Answer 2

an individual who is or has, at any time in the preceding year, been entrusted with prominent public functions and an immediate family member, or a known close associate, of such as person.

Question 3

Which EU measure defines a PEP?

Answer 3

EU Directive 2006/70/EC.

Question 4

Which functions does the EU consider to be PEP?

Answer 4

• Heads of government, state, deputy ministers, assistant ministers.
• MPs
• Supreme and high court
• Courts of auditors or boards of central banks
• Ambassadors, charge d’affaires.
• High ranking military officiers
• Members of administrative, management or supervisory boards of state owned enterprises.

Question 5

How did the 4MLD expand the definition of a PEP?

Answer 5

1. Includes members of governing bodies of political parties, directors, deputy directors and members of a board of an international organisation.
2. Includes spouses of children and parents.
3. Close associates are those who have joint beneficial ownership of legal entities with a PEP.
4. Close associates are those who have beneficial ownership of a legal entity which is known to be set up for the de facto benefit of a PEP.

Question 6

Who are excluded from EU PEP definition?

Answer 6

• Middle ranking and junior officials.