Politically Exposed Person (PEP)

An individual who holds or has held a prominent public function at the national or international level, such as a head of state, senior politician, high-level government official, judicial or military leader, or executive of a state-owned enterprise. Immediate family members and close associates of such individuals are also considered PEPs due to their potential access to or influence over public resources and policy decisions.

[
Code
AT0025
]
[
Name
Politically Exposed Person (PEP)
]
[
Version
1.0
]
[
Category
Government & Public Sector
]
[
Created
2025-03-12
]
[
Modified
2025-04-02
]

Related Techniques

PEPs facilitate or invest in construction projects by:

  • Leveraging political influence to award government contracts or channel public funds to co-conspirators.
  • Splitting ownership stakes or engaging in sub-developer arrangements to conceal illicit gains.
T0051
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Politically exposed persons exploit their prominent public positions to generate illicit funds through bribes, embezzlement, or kickbacks. They move these proceeds through intermediaries or shell companies, making it harder for financial institutions to trace the true source and ownership of assets.

PEPs exploit diplomatic channels by:

  • Physically transporting illicit funds or valuables in diplomatic pouches, which are exempt from host-state inspection.
  • Using their positions within state-owned enterprises to open or operate accounts under the guise of official transactions, concealing corruption proceeds or bribes from deeper scrutiny.

These privileges hinder financial institutions’ ability to conduct thorough due diligence and investigate suspicious activity, as diplomatic immunity and official cover often override routine checks.

Politically Exposed Persons (PEPs) wield influence over environmental regulations or resource allocation, which criminals exploit. They:

  • Facilitate or benefit from illegal resource extraction by leveraging high-level positions.
  • May hold hidden beneficial ownership stakes in entities involved in illegal logging, fishing, or waste dumping.
  • Increase challenges for financial institutions, as standard due diligence can be circumvented through their elevated status or network connections.

Politically exposed persons exploit sham consulting engagements for large-scale corruption by:

  • Channeling bribes or embezzled funds through inflated advisory contracts to conceal official misconduct.
  • Leveraging their status to evade scrutiny and blend illicit proceeds with legitimate payments, frustrating financial institutions’ corruption detection efforts.

Politically Exposed Persons (PEPs) can be listed as policyholders or beneficiaries for annuity contracts, leveraging their influence or connections to avoid scrutiny. This arrangement hampers financial institutions' ability to verify the legitimacy of premium payments or withdrawals.

PEPs may appear as beneficial owners or major stakeholders in privately held investment companies, raising the risk that:

  • Illicit funds from corruption or bribery are blended with legitimate investments.
  • Authorities face heightened challenges tracing or questioning unusually large inflows connected to political offices.

Financial institutions must exercise enhanced scrutiny when PEPs are involved, as the origin of assets and influence can further obscure potential misconduct.

PEPs exploit VIP junket arrangements to channel potentially misappropriated funds into casinos under the guise of legitimate gambling. They take advantage of cross-border junket services by:

  • Avoiding enhanced scrutiny through discretionary VIP rooms and private credit lines.
  • Merging illicit proceeds with perceived high-stakes gaming activity, complicating financial institutions’ attempts to verify the source of funds.

PEPs and their close associates exploit privileged access to public resources by:

  • Leveraging positions of influence to authorize or expedite illicit disbursements.
  • Employing family members or proxies to open accounts and obscure beneficial ownership.

Financial institutions face elevated risks due to the large scale and international reach of such transactions.