An examiner or auditor reading a PEP screening file wants three answers: which function made the person a PEP, which country entrusted it, and which rulebook the firm applied. One job title can give different answers. Under FCA guidance a UK circuit judge is not a PEP, while Austria's list names the judges of its Supreme Administrative Court.
What are the three types of PEPs?
FATF defines a PEP as "an individual who is or has been entrusted with a prominent public function" (guidance, paragraph 1). Its glossary in the FATF Recommendations, unchanged in the June 2026 edition, sorts PEPs by who entrusted that function:
- Foreign PEPs hold or held it for another country: heads of state or government, senior politicians, senior government, judicial or military officials, senior executives of state owned corporations and important political party officials.
- Domestic PEPs hold or held the same kinds of function for the firm's own country.
- International organization PEPs sit in the senior management of a body set up by treaty, such as the UN or NATO: directors, deputy directors and board members.
What decides whether a PEP is foreign or domestic?
FATF's guidance on PEPs adds the test that settles most disputes. The country that entrusted the function decides the type (2013, paragraph 12). Nationality and home address do not. UK law uses the same test: a domestic PEP is one the United Kingdom entrusted.
Take an Irish national appointed deputy director general of the World Trade Organization who opens an account in Dublin (illustrative): her Irish bank files her as an international organization PEP, because the WTO gave her the role.
Why are foreign PEPs treated differently from domestic PEPs?
Two deputy ministers open accounts at a Warsaw bank on the same morning, one Polish and one from a country where the bank has no branch (illustrative). Under FATF Recommendation 12, the second is a foreign PEP and always gets enhanced due diligence. The first is a domestic PEP, so the bank assesses the risk of the relationship first and applies the enhanced measures only when that risk is higher (guidance, paragraphs 23, 26 and 27).
FATF's reason is distance. A bank may know little about what a reasonable income looks like for an official in another country (paragraph 22). It also warns that a bank in a market with known corruption problems may be more exposed to its own country's PEPs (paragraph 19).
Is there a domestic PEP in US rules?
National rules part ways here. The EU directive applies the same measures to domestic and foreign PEPs (Article 20). UK domestic PEPs have started from a lower level of risk since 10 January 2024. In the US, the BSA rules do not define PEPs at all, and the 2020 joint statement does not count US public officials as PEPs.
Which positions qualify as a PEP?
Table 1. Which positions qualify as a PEP, by rulebook (as of November 2026)
| Function | FATF glossary | EU directive (AMLR from 10 July 2027) | UK regulation 35 with FCA FG25/3 | US 31 CFR 1010.605(p), foreign figures only |
|---|---|---|---|---|
| Heads of state and government, ministers, deputy ministers | Yes | Yes, assistant ministers too | Yes | Yes, as senior foreign officials |
| Members of parliament | As senior politicians | Yes | Yes, devolved legislatures included | Senior officials of a foreign legislature |
| Judges | Senior judicial officials | Top courts whose rulings face no further appeal | Supreme Court judges only | Senior officials of a foreign judiciary |
| Central bank boards, courts of auditors | Not named | Yes | Yes | If they hold substantial authority |
| Ambassadors, senior military officers | Senior government or military officials | Ambassadors, chargés d'affaires, high ranking officers | UK posts at Permanent Secretary or deputy level; Vice Admiral, Lieutenant General, Air Marshal | Senior officials of a foreign military |
| Leaders of state owned enterprises | Senior executives | Board and management members | For profit firms over 50% state owned or state controlled | Senior executives of foreign government owned firms |
| Political party officials | Important party officials | Governing bodies; AMLR: parties with national seats, or local seats for 50,000 or more inhabitants | National governing bodies with significant executive power | Senior officials of a major foreign party |
| International organization officials | Directors, deputy directors, board members | The same; AMLR adds representatives to a member state or the EU | Public bodies such as the UN and NATO, not sporting federations | Not a listed category |
| Heads of regional and local government | Possible, by size (guidance paragraph 38) | Not named; AMLR: 50,000 inhabitants or more | Devolved governments yes, local government no | Only as senior officials with substantial authority |
All four rulebooks list functions, not names. FATF leaves the exact level of seniority open because it depends on a country's size, population, budget and the way its government is organized, and it accepts that prominent functions can exist at state or municipal level (guidance, paragraph 38).
The EU turned that into national detail. Article 20a of the directive made each member state list its qualifying functions, and the Commission published the 27 national lists, with those for international organizations and EU bodies, on 10 November 2023. Austria's entry, for example, names the judges of its Supreme Court, Constitutional Court and Supreme Administrative Court, and officers above the rank of Lieutenant General. The AMLR definition takes over from the directive's on 10 July 2027.
The UK list in regulation 35(14) follows the EU categories, and the FCA's FG25/3 narrows them for UK roles. The US definition in 31 CFR 1010.605 covers only foreign figures with substantial authority over policy, operations or government owned resources.
What changed in 2026?
- June 2026. FATF updated its Recommendations, and the glossary's PEP definitions read word for word as in the October 2025 edition.
- 1 November 2026. AMLA's consultation page lists 11 public consultations opened between 16 December 2025 and 7 October 2026. None covers PEPs.
- By 10 July 2027. AMLA owes guidelines on identifying close associates and on the risk attached to each category of PEP (AMLR Article 42(2)). The AMLR definitions apply the same day.
Which public officials are usually not PEPs?
Most "is X a PEP" questions turn on rank first and on the regime second, and for a customer in one of these posts the answer is usually no:
- Middle ranking and junior officials. The FATF glossary and Article 3(9) of the directive both exclude them.
- Judges below the top courts. In the UK, FG25/3 counts only Supreme Court judges.
- Embassy staff below the head of mission. The EU and UK texts name ambassadors and chargés d'affaires, not consuls. Belgium's and Bulgaria's national lists add consuls, and Slovenia's names the heads of consular posts on its diplomatic list, honorary consuls included, so check both the appointing and the host country's list.
- Police officers below the top ranks. No rulebook names the police. National lists name police chiefs: Czechia its police commissioner and regional directors, Spain the director general of the National Police, Portugal the chief superintendents of the Public Security Police.
- Local officials. FG25/3 excludes UK local government, while Bulgaria's and Cyprus's lists, for example, name mayors.
- US officials, at US banks. The 2020 joint statement excludes them.
Rank still matters when the official is not your customer. FATF warns that middle ranking officials can act for a PEP, and that role can count as a customer risk factor (paragraph 37).
Who counts as a family member or close associate of a PEP?
FATF applies Recommendation 12 to a PEP's family members and close associates as well, and leaves it to each country to say who they are (paragraph 46). In some cultures the close family is parents, siblings, spouses and children; in others it reaches grandparents, cousins or a clan (paragraph 48).
Written rules draw the line in different places. The EU directive names a spouse or equivalent partner, the children with their spouses or partners, and the parents. FG25/3 reads siblings into the UK list and lets a firm take in aunts and uncles once it has assessed a PEP as higher risk. The US definition also reaches the spouse's family: spouses, parents, siblings, children, and a spouse's parents and siblings.
A close associate is defined through ownership: someone known to share the beneficial ownership of a company or legal arrangement with a PEP, to have other close business relations with one, or to own alone a vehicle set up for a PEP's benefit. UK regulation 35(15) lets a firm rely only on what it holds and on credible public information.
Is a deputy minister's brother a PEP?
A customer's road building company bids for transport ministry contracts, and his brother is the deputy minister there (illustrative). Whether the customer is a PEP family member depends on the rulebook and, from July 2027, on the date.
- FATF guidance defines family members as relatives by blood or by marriage (paragraph 11) and leaves the reach to each country (paragraph 46), so the brother can fit.
- Under the EU directive today, siblings are not on the list of family members.
- Under the AMLR, from 10 July 2027, a sibling counts as a family member when the PEP is a head of state or government, a minister or a deputy or assistant minister, so he becomes one.
- In the UK, FG25/3 counts siblings; for a British ministry the lower domestic starting point applies.
- In the US, for a foreign ministry, siblings sit inside the senior foreign political figure definition that the BSA private banking rule uses.
He counts as a close associate only if the two share ownership or close business ties. Either way, the bids carry the risk. FATF names final approval over government procurement as one sign of a prominent function (paragraph 41), and these bids go to the brother's own ministry. The corruption risk sits in the award process whichever definition applies, so the file needs the source of funds behind each contract payment and the name of whoever approved each award.
What do PEP Class 1 and Class 2 mean in a screening result?
A UK bank's screening returns a Class 2 hit on a town councilor (illustrative). FG25/3 says UK local government is not a PEP function. The analyst clears it and notes why.
Read the free PEP check classes the same way. Class 1 holds heads of state and ministers, senior politicians, central bank officials and supreme court judges; Class 2 holds the heads of state owned enterprises, senior civil servants and regional and local officials; family members and close associates form their own category. A class sorts hits; the rulebook decides who is a PEP. complead, formerly Sanction Scanner, screens against its PEP data and the rest of its 3,500+ sanctions, PEP and watchlists from 220+ jurisdictions, refreshed every 15 minutes. Agents close routine cases with the evidence attached, and an analyst decides which rulebook a hit meets.
How long does someone stay a PEP?
FATF asks for a risk based judgment with no fixed limit. The EU and the UK set a floor of 12 months or more from the day the person leaves office, and the US definition covers current and former senior foreign political figures with no end date. The type can change too: a former finance minister who joins an international organization's board is now also an international organization PEP.
