What is a PEP?
A PEP is a politically exposed person. Part of the Wwft client screening is that we are obliged to check whether the client, a UBO or the pseudo-UBO is a PEP. If that is the case, we will have to conduct an enhanced client screening.
In any case, a PEP is someone who is entrusted with one or more of the following prominent public functions, has been entrusted for the past year or is about to be entrusted with such a function. Some family members of such a person are also PEPs. This is the case for a parent, the spouse (or equivalent) or a child or spouse of a child (or equivalent). The same applies to persons who are known to have a close business relationship with a person with a PEP function.
Examples of PEP functions:
- head of state, head of government, minister, junior minister or state secretary;
- member of parliament or member of a similar legislative body (e.g. the senate or parliament);
- member of the board of a political party;
- member of a supreme court, constitutional court or other high court that delivers judgments against which, except in exceptional circumstances, there is no appeal, for example in the Netherlands: Council of State (Raad van State), Supreme Court (Hoge Raad), Trade and Industry Appeals Tribunal (College van Beroep voor het bedrijfsleven) (and/or the Central Board of Appeal (Centrale Raad van Beroep));
- member of an audit office or of the board of a central bank;
- ambassador, chargé d’affaires or senior officer of the armed forces;
- member of the management, supervisory or governing body of a state-owned company;
- director, deputy director, member of the board or holder of an equivalent function in an international organization (such as the International Court of Justice, the United Nations, the institutions of the European Union, the North Atlantic Treaty Organization and the World Trade Organization);
- another function similar to the functions listed above.
Intermediate or junior officers are not covered by the above functions. The Dutch government has made a list of functions that are ‘politically prominent’ (PEP functions) in the Netherlands (but PEP functions can also be foreign functions).