How we represent political office-holders

Information about politically-exposed persons is organized by when an individual held a position imbued with political power, and the significance associated with that position. You can use this to develop a detailed understanding of a customer or the target of an investigation.

The PEPs data may be used via the bulk data or the API. This page further documents how PEP position information is represented in our dataset so that you can make best use of it.

For typical PEP identification

People in our dataset who are considered to be PEPs are tagged with the role.pep topic. The position data associated with the person further indicates

  • Their role
  • The country the position relates to, allowing you to identify foreign PEPs
  • The time period the position was held, when available

Fine-grained control

We progressively classify more and more positions according to our taxonomy of role type and the scope of their jurisdiction. This can be used to implement more detailed risk policies, or provide additional information when manually inspecting a customer's PEP classification.

Newly-detected PEPs and positions are immediately included in our dataset for completeness, but due to the changing nature of the data, the detailed classification takes place as an additional step and is not immediately available.

See our detailed PEP classification taxonomy.

When is someone included as a PEP in the data?

People are considered PEPs if they currently occupy, or have previously occupied, any of the positions that can be placed under the categories below. How long they are considered a PEP after leaving the position is dependent on the nature of the position and the quality of the data available. While our categorisation supports sub-national and local-level PEPs, we give priority to national level.

OpenSanctions considers people in the following non-exhaustive list PEPs, prioritising our coverage of the data as follows:

Key PEP categories
National head of government, head of state (President, Prime minister, Queen)
National executive/cabinet
National legislature
National court judges, prosecutors
Security and intelligence services including militaty, police
Central Bank leadership
Diplomatic missions
Intergovernmental organizations senior leadership, legislators
Regional/sub-national head of government (Governor, Premier)
Regional/sub-national executive/cabinet
Regional/sub-national legislature
Regional/sub-national court judges
State-owned enterprises, public entities, agencies reporting to national government
Political party leadership
Local head of government (Mayor)
Local executive (e.g. Mayoral committee member)
Local legislature

Given sufficient information from the source, we consider position-holders PEPs for the following durations after they have left the position:

  • National positions: 20 years
  • Intergovernmental positions: 20 years
  • All other positions: 5 years

If an end date is not available, we apply the following process

  • PEPs from sources that do not provide end dates, but are known to only and reliably maintain current office-holders, are assumed to be current (government-published sources like CIA World Leaders, MEPs).
  • PEPs from sources where no end date can not be assumed to mean current:
    • People who have died within the past 5 years are included, allowing for ongoing investigations and influence of their relations close associates.
    • People are included but their status considered unclear for 120 years after their date of birth, or 40 years after they entered the position, if known.
    • People without any birth, death or position dates are excluded from the database.

In the data

The Occupancy entity's status property reflects the decision from the above rules:

  • current means the data indicates they currently occupy the position.
  • ended means they do not occupy the position any more, but are still within the period in which we consider them a PEP
  • unknown means neither current nor ended could be applied, but they are still considered a PEP according to the remaining rules and the available data.

See more on how PEP position details are represented in the data.

Best practices

Position classifications are added as soon as possible. As new data is automatically imported, new positions may be created but not yet fully classified. They are included for completeness, and further details will be introduced as the data is reviewed by our team. Do not assume that complete position classification topics are always available.

If you want to monitor specific types of positions using OpenSanctions data, we recommend removing unneeded positions (and their position-holders) based on classification topics that disqualify them. In this way, cases where positions are added but are not yet classified will be included in your matches, rather than being ignored because they do not yet match your search criteria.

For example, if your risk policy requires considering national government but not local government, ignore any positions with the gov.muni topic. Do not rely on only including positions with the gov.national topic. If new positions are added to the dataset, e.g. a government creates a new ministry and the position is automatically included in our dataset but is not yet classified with the gov.national and gov.executive topics, they will still be included.