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Who would be considered a Politically Exposed Person (PEP)?


“A Politically Exposed Person (PEP) is a natural person who is or has been entrusted with prominent public functions and includes his/her immediate family or persons known to be close associates of such persons, but shall NOT include middle ranking or more junior officials.”




A PEP is considered to be a High-Risk Customer (HRC) if seen as prone or susceptible to corruption. It is therefore essential for any PEPs to be declared in the KYC. This will allow the client to consider the risks and risk appetite and therefore accept or exit the relationship.

When determining whether a particular holder of a public function has the requisite seniority, prominence or importance to be categorised as a PEP, the following factors should be considered:


  • Official responsibilities of the individual’s function

  • The nature of the title (honor