What does politically exposed person (PEP) mean under the Money Laundering Act?

Politically exposed persons (PEPs) are individuals in high public positions or closely connected to them. Under the Act on Detecting and Preventing Money Laundering and Terrorist Financing, Paytrail is legally required to identify if a company using our service has PEP involvement. Learn who qualifies as a PEP, which family members or associates are included, and why this matters for compliance and company operations.

Definition of a politically exposed person

A politically exposed person (PEP) is a natural person who has been entrusted with a prominent public function during the last 12 months. This can include:

  • Heads of state, ministers, deputy or assistant ministers
  • Members of parliament or governing bodies of political parties
  • Judges of supreme or constitutional courts
  • Members of state audit bodies or central bank boards
  • Ambassadors, chargés d’affaires, or senior military officers (general or higher)
  • Directors or board members of wholly state-owned enterprises
  • Directors, deputy directors, or board members of international organizations

Family members and associates of a PEP

A person can also be politically exposed through family ties or close associations. This means that relatives and close partners of a PEP are also considered politically exposed. The following groups are included:

  • Spouses or partners considered equivalent under national law
  • Children and their spouses or partners
  • Parents
  • Close business associates

Read also: Why are you asking about the beneficial owners of my company? 

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