How we model political offices as entities, classify them by branch and level, and determine how long former office-holders remain in the database.
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How we model political offices as entities, classify them by branch and level, and determine how long former office-holders remain in the database.
Our PEPs data may be used via the bulk data or the API. This page further documents how PEP position information is represented in our data so that you can make the best use of it.
A PEP record in OpenSanctions connects three entity types from the FollowTheMoney (FtM) data model:
Position — a specific office that can be held, such as a seat in a national parliament or a cabinet role.Occupancy — a link between a Person and a Position, representing the period during which they held the office.Person — tagged with the role.pep topic once linked to a qualifying Position via an Occupancy. In the nested entity representation (available via the API and the targets.nested.json bulk format), the positionOccupancies property lists all of a person's linked occupancies.A person is classified as a PEP if they currently hold, or have previously held, any of the positions below. How long they remain classified after leaving office depends on the nature of the position and the quality of the data available — see Retention windows.
Each Position is tagged with one or more topics from a controlled vocabulary, allowing risk-tiered filtering beyond the binary PEP/non-PEP distinction. Topics fall into two dimensions: role (the function or branch of the position) and jurisdiction (the level of government). Most positions carry one topic from each dimension. When a position spans multiple roles or jurisdictions, the topic representing the greatest level of influence is used.
New positions are added to the database promptly; detailed topic classification follows as a separate step.
The following list is non-exhaustive. We prioritize national-level coverage; subnational and local positions are included where we have reliable, maintained sources.
| Category | Examples | Role | Jurisdiction |
|---|---|---|---|
| Head of state or government | President, Prime Minister, Chancellor, Monarch | gov.head | gov.national |
| National executive | Ministers, deputy ministers, political secretaries of state | gov.executive | gov.national |
| National legislature | MPs, senators, assembly members | gov.legislative | gov.national |
| Supreme judiciary | Supreme court justices, constitutional court members | gov.judicial | gov.national |
| Flag officers | Generals, admirals, intelligence agency heads | gov.security | gov.national |
| Central bank and financial regulators | Governor and board members of central banks and financial regulatory authorities | gov.financial | gov.national |
| Ambassadors | Heads of mission, High Commissioners, Permanent Representatives | role.diplo | |
| State-owned enterprises, public entities, and agencies | Board members and C-suite reporting to national government | gov.soe | gov.national |
| Intergovernmental organization leadership | UN Secretary-General, IMF Managing Director, World Bank President | gov.executive | gov.igo |
| Intergovernmental organization legislature | Members of the European Parliament | gov.legislative | gov.igo |
| Intergovernmental organization governance boards | IMF Executive Board, World Bank Board of Governors | gov.financial | gov.igo |
| Political party leadership | Party leader, deputy leader, secretary-general | pol.party | |
| Religious leadership | Senior religious leaders with significant political influence | gov.religious | |
| Regional/subnational head of government | Governor, Premier | gov.executive | gov.state |
| Regional/subnational executive | Regional ministers, cabinet members | gov.executive | gov.state |
| Regional/subnational legislature | Regional assembly members | gov.legislative | gov.state |
| Regional/subnational judiciary | Regional court judges | gov.judicial | gov.state |
| Regional/subnational state-owned enterprises, public entities, and agencies | Board members and C-suite reporting to regional government | gov.soe | gov.state |
| Local head of government | Mayor | gov.executive | gov.muni |
| Local executive | Mayoral committee members | gov.executive | gov.muni |
| Local legislature | City councillors | gov.legislative | gov.muni |
Leaving office doesn't immediately end PEP status. Former office-holders retain influence, relationships, and in some cases exposure to investigation long after their last day in post.
| Position level | Retention after leaving office |
|---|---|
National head of state or government (gov.head + gov.national) | 50 years |
Other national-level (gov.national) | 20 years |
Intergovernmental (gov.igo) | 20 years |
Diplomatic (role.diplo) | 20 years |
| All other positions | 5 years |
There is no single, globally agreed rule for how long PEP status should persist after someone leaves office. The standards diverge sharply: the Financial Action Task Force (FATF) prescribes no fixed period and leaves it entirely to a risk-based assessment; the EU sets a 12-month minimum with open-ended extension; and several countries (Canada and Switzerland for foreign officials, Japan, New Zealand) treat PEP status as effectively permanent. In national regimes that do fix a period, these range from one year to five.
Against that inconsistency, the windows above are a deliberate, risk-based calibration on our part. They are designed to satisfy the broad, global range of retention expectations — erring well past the 12-month floor most regulators set — without adopting the most extreme position, under which a person classified once remains a PEP for life. We treat that "never declassify" approach as unhelpful: it inflates the database with stale exposure and pushes the cost of distinguishing real risk onto you.
These windows are therefore our judgment, not a regulatory requirement, and no single jurisdiction mandates exactly this schedule. If your own risk policy requires different windows — longer, shorter, or permanent retention for certain categories — you can implement them yourself using the occupancy end date we record on every position.
Biological limits also apply, regardless of these windows:
Relatives and close associates of PEPs carry the role.rca topic. We include RCAs documented in our data sources — primarily Wikidata and official declarations — and don't independently research family or business networks.