10 PEP Categories and Roles You Should Know

A President Is Easy to Spot. What About Everyone Else?

A president is an obvious PEP. A state-owned bank executive, a senior judge, a military commander, and a political party leader can be too.

Lenín Moreno became a politically exposed person the moment he took office as vice president in 2007, years before any bribery accusations. On August 28, 2026, a Quito court convicted him on bribery charges tied to the Coca Codo Sinclair hydroelectric plant, sentencing him to five years and a permanent ban from public office. His wife, daughter, and two brothers were convicted alongside him in the same case.

The public function made him a PEP years before the conviction. PEP status marks that function, current or former, independent of guilt or innocence.

This guide covers 10 PEP categories and roles, grouped by type of power, plus where classification gets harder to apply.

So What Makes Someone a PEP?

A politically exposed person is someone who holds, or has held, an important public office. The international definition can be found in FATF Recommendation 12:

FATF guidance provides examples:

Heads of state and government;
Senior political figures;
Important government officials;
Important judicial officials;
Important military officials;
Important executives of state-owned enterprises;
Important officials of political parties

This list is not exclusive. The following are the types of political exposure under PEPs.

As stated by FATF, these measures are purely preventive in nature. The fact that the role has been classified as a PEP only indicates a position of access, not criminal activity.

Also Read – The Growing Role of Beneficial Ownership Intelligence in 2026

The 10 PEP Categories: Where Does Public Power Sit?

Public power exists in several institutions: the executive branch, the courts, the armed forces, state-owned companies, political parties, and international bodies. Each of the categories below reflects a different kind of authority.

Executive Power

Heads of state and government, presidents, prime ministers, monarchs, and equivalent national leaders control appointments, national budgets, and policy across every government institution.

Senior government officials, ministers, deputy ministers, and secretaries of state carry that same kind of authority within a narrower scope. A minister qualifies. A mid-level employee in the same ministry stays outside the definition.

Institutional Power

Legislators—MPs, senators, and members of national legislative bodies—hold authority at the national level, distinct from a seat on a local or municipal council.

Senior judicial figures—including senior Supreme Court and Constitutional Court judges—make an impact on the policies made by the government, elections for those who have a chance to win, and how the government handles the use of public money in making decisions as part of their decision-making. Public attention to a PEP’s status tends to start at the politician level, thus missing this group.

Senior military leaders who oversee the defense budget and strategic decisions fall into this category. It is not rank or a uniform alone that will put someone above the threshold; command over budgets and strategy does.

The senior levels of law enforcement (police) and security organisations have comparable levels of control and influence over the operational elements of national security and public safety budgets.

State-Linked Economic and Political Power

A government official does not have to hold an elected position (a title) for him/her/it to be a PEP. State-owned companies are now often under the direct management of the government. FATF lists high-ranking officers of these state-owned companies as being part of its definition. A director or senior officer of a state-owned company is able to enter into contracts with their respective governments for billions of dollars. They also control the flow of government money. This is exactly what happened when Morena signed the Sinohydro contract. As of 2023, there were over thirty thousand large state-owned enterprises operating around the world, employing more than forty-five million employees and managing nearly two hundred fifty billion U.S. dollars in assets.

Can someone who is an official of a political party be a PEP?

Yes. While one may think that it takes a title from the government to be considered a PEP, this is not the case. Political power exists outside of titles. Anyone who has the ability to select candidates, fund parties, or determine party policies is able to effectuate government decisions without having to hold a title from the government.

International and Diplomatic Power

International organisation officials

Division heads and senior decision-makers at qualifying international organisations hold this role. General staff employment at these bodies falls well short of that authority; only decision-making at the division-head level reaches it.

Ambassadors, governors, and other prominent officials

These roles carry public authority outside the national government structure. Representing a government abroad or governing a jurisdiction with independent authority is what earns the classification.

PEP Classification: Domestic, Foreign or International Organisation?

The categories above are sorted further by jurisdiction. A domestic PEP holds a prominent public function in their own country. A foreign PEP holds one in a country other than the one doing the assessment. An international organisation, PEP, holds one within a qualifying international body.

This split traces to Article 52 of the UN Convention against Corruption, which FATF’s guidance builds on. The label changes based on where someone holds the function, while the underlying question stays the same: what public function does this person hold, and how prominent is it?

How PEP Status Differs From a Sanctions Hit

Placing someone inside these categories still leaves a separate question unanswered: whether that person also appears on a sanctions list. A PEP can go unsanctioned, and the reverse holds too. One classification describes a public function; the other reflects a sanctions designation.

Key distinction	PEP	Sanctioned person
Why identified	Public function	Sanctions designation
What it indicates	Position and exposure	Legal or policy restriction
Proves wrongdoing	Position only, never guilt	A restriction alone, apart from any proven guilt
Source type	PEP records	Sanctions lists
Can someone have both	Yes	Yes

Also Read – Sanctions Screening False Positives: Causes, Risks, and Solutions

Why PEP Relatives and Close Associates Are Tracked Separately?

The same distinction applies again, this time to the people connected to a PEP rather than the PEP alone. FATF’s framework covers family members and close associates too, since financial or business ties to a PEP can carry comparable reputational exposure.

Marriage to a PEP leaves a spouse outside PEP status, and the same holds for a business associate who works with one. Enhanced measures and added risk considerations can still apply to defined relatives and close associates under rules that exist independently of PEP classification.

His wife, daughter, and two brothers carried relative status through their connection to Moreno, the reason enhanced measures would apply to them under AML frameworks. Their criminal convictions in the bribery case rest on a different basis, criminal liability, the kind of record covered separately in a warrants and criminal entities database rather than a PEP one. None of them held a public function under the categories above.

You Found a Name on a PEP List. What Should You Check Next?

With the categories, jurisdiction, sanctions distinction and relative rules all in place, applying them to an actual record shows how they work in practice. Take a record that lists “Maria Santos, Director, National Energy Company”, the kind of entry that shows up on a PEP database search. Determining her status takes a specific set of checks.

Is the company state-owned or state-controlled?
What exactly is her position?
Is she senior enough for the applicable definition?
Which jurisdiction’s PEP rules apply?
When did she hold the position?
Is she a current or former PEP?
Are relevant relatives or close associates identified separately?
Is the underlying record current and sourced?

The same eight checks apply to any name on any list, including roles well beyond executives at state-owned companies.

Also Read – Entity Intelligence vs Name Matching: What Changes in 2026?

PEP Categories and Roles: Quick Reference

The checklist above works name by name. This table maps all 10 PEP categories against the type of authority each one carries, for a faster lookup.

PEP category	Example roles	What makes it relevant
Heads of state and government	President, Prime Minister	National executive authority
Senior government officials	Ministers, senior officials	Public decision-making authority
Legislators	MPs, senators	National legislative authority
Judicial officials	Supreme court judges	Judicial authority
Military officials	Senior commanders	Defence authority
Law enforcement and security officials	Senior police and intelligence leaders	Security authority
State-owned enterprise executives	Senior directors	State-linked economic authority
Political party officials	Senior party leaders	Political influence
International organisation officials	Division heads, senior officials	International public function
Ambassadors, governors, other officials	Ambassadors, governors	Public and diplomatic authority

PEP Classification Starts With the Role

The categories above look straightforward until a specific name shows up. The senior executive of a state-owned company, the judge with national authority and the party official without a government title get missed most often, since none of them hold a title as recognisable as president or minister.

To classify any name correctly:

Match the role to one of the 10 categories above.
Confirm the jurisdiction: domestic, foreign or international organisation.
Check sanctions and criminal records separately from PEP status.
Flag defined relatives and close associates under their own rules.
Verify the record is current and sourced before acting on it.

SanctionsDatabase organises its PEP list using these same PEP categories, kept current alongside its sanctions and criminal record datasets.

Frequently Asked Questions

What is a PEP?

Someone who holds, or has held, a prominent public function. Seniority and scope of the role decide status beyond simple government employment.

What is the difference between a domestic and foreign PEP?

A domestic PEP holds a prominent public function in their own country. A foreign PEP holds one in a different country than the one doing the assessment.

Are PEP relatives automatically PEPs?

Relatives qualify as PEPs only when they hold a prominent public function of their own. Connection to a PEP triggers a different set of rules, outside PEP classification proper.

Can a state-owned enterprise executive be a PEP?

Yes. FATF lists senior executives of state-owned corporations directly among its PEP examples, given their access to government-linked funds and contracts.

Does being a PEP mean someone is involved in financial crime?

PEP status reflects the public function someone holds, independent of involvement in financial crime. Conduct is addressed through separate records.