Politically exposed persons

Senior public office — running a country, controlling a budget, appointing officials, negotiating contracts — creates opportunities for corruption that ordinary employment doesn't. The financial system responds to this through the concept of a politically exposed person (PEP): someone whose position warrants closer scrutiny when they open accounts, move money, or do business with regulated institutions.

The regulatory definition#

Most countries' anti money-laundering (AML) frameworks define PEPs as individuals who hold or have held a prominent public function, and require financial institutions to apply enhanced due diligence when dealing with them. What counts as "prominent" varies: some jurisdictions enumerate specific roles in law; others leave it to the institution's risk assessment. The threshold is generally drawn at senior national positions — cabinet ministers, members of parliament, senior judges, central bank governors, ambassadors, military leadership — with treatment of subnational officials varying by country.

Three categories of PEP are commonly distinguished:

• Foreign PEPs — office-holders in another country, typically subject to a higher level of scrutiny because the institution has less visibility into their domestic context.
• Domestic PEPs — the same category of office-holders in the institution's own jurisdiction. Whether stricter measures apply depends on the institution's risk assessment.
• International organization PEPs — senior officials of intergovernmental bodies such as the UN or IMF.

Former office-holders remain PEPs for a period after leaving office. The reasoning is that influence, relationships, and risk don't end on the last day in post. How long varies: some jurisdictions set a fixed period; others require a continuing risk-based assessment. The retention windows we apply are tiered by the seniority of the position.

How we approach PEPs#

Our database is built around the office, not the person. We model each political position as a distinct entity — with its own country, classification, and dates — and link it to the individuals who have held it. This means our data can answer not just "is this person a PEP?", but also which office makes them one, in which country, and for how long.

The database is published as EveryPolitician, where you can browse coverage by territory. Our classification methodology and source code are public.

What classification means#

The term "politically exposed person" is used by banks and financial institutions to describe anyone who holds or has held a prominent public function. It covers heads of state, cabinet ministers, national legislators, senior judges, central bank governors, ambassadors, military leadership, and similar positions, as well as their close family members and associates.

Being classified as a PEP is not an allegation. It is a risk category that exists because senior public office creates a specific kind of exposure to corruption and financial crime — not because the individual is suspected of anything. A financial institution's obligation when dealing with a PEP is to understand the person's source of funds and wealth more thoroughly than for an ordinary customer. In practice that means additional questions at onboarding or during account reviews — not a refusal of service.

The screening obligation sits with financial institutions. They use structured data from providers like us to identify whether a customer holds or has held a qualifying office. We publish data about public offices and the people who hold them; we do not make decisions about individual customers or accounts.

If a PEP is missing#

PEP data is source-dependent: we include what is documented in publicly available sources. If someone is missing, the right response depends on why.

If they appear on a source we already ingest: A current member of parliament missing from OpenSanctions when they should be there is a data issue. Contact support with a link to the relevant source and we'll investigate quickly.

If they appear on a government-published list we don't yet ingest: We evaluate source suggestions against our inclusion criteria and add qualifying sources to our backlog. Submit a suggestion.

If they're not on any government-published list: The most practical route is to add or improve their profile in Wikidata, which is one of our upstream sources. If you want to help map out political positions and their office holders, please check out the EveryPolitician.org contribution guide.