Topic · Politically exposed person
What is a politically exposed person?
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A politically exposed person, or PEP, holds or has held a prominent public function. Section 1(12) of the German Money Laundering Act (GwG) also includes immediate family members and known close associates. Screening business partners involves checking names against PEP lists and documenting the result in a traceable way.
Who is a politically exposed person?
A politically exposed person holds or has held a prominent public function, such as a government minister, member of parliament, senior military officer or head of a state-owned enterprise. The relevant provision is Section 1(12) of the German Money Laundering Act (GwG).
Are family members and close associates included?
Yes. Under Section 1(12) of the German Money Laundering Act (GwG), politically exposed persons also include immediate family members and known close associates. They are therefore included in screening.
How long does someone remain a PEP?
The status relates to a prominent public function that a person holds or has held. After leaving office, the person therefore remains on the lists for as long as the entry exists.
How does PEP screening differ from sanctions list screening?
The Sanctions list screening checks whether an individual or company is subject to sanctions and a making-available prohibition . A PEP match, by contrast, is a risk indicator: PEPs are considered to present an increased risk of corruption and bribery because of their position.
Assess sanctions risk in your own business
PEP screening is one part of checking business partners. The other is screening against sanctions lists. These two pages help you get started.
- Self-assessment: how high is your sanctions risk?
7 questions about customers, suppliers and freight forwarders. Takes around 2 minutes. You receive specific next steps at the end.
- Financial sanctions list on Justizportal: what it covers
This page explains which sanctions the list on Justizportal (German federal/state justice portal) contains and how to document a check.
What obligations does a PEP match trigger?
This affects businesses entering into relationships with natural persons with increased risk exposure, as well as businesses generally required to comply with sanctions and making-available prohibitions. Affiliated companies with ownership of 50 percent or more are also included. Screening helps identify risks in the business relationship early and document them in a traceable way.
How do you check whether a business partner is a politically exposed person?
Upload a document or enter a name, followed by OCR recognition, screening against 20 official PEP, sanctions and crime lists from 18 jurisdictions (OpenSanctions database) and a traffic-light result. Output as an audit-proof PDF with a verification URL.
Check your first business partner in 30 seconds
Screening against 20 official sanctions and PEP lists from 18 jurisdictions, with an audit-proof PDF.
Create an account for your screening certificate. Result in 30 seconds.
Am I Compliant is an information and data processing service and does not provide legal advice. Results are research findings; the legal assessment and decision rest with the user.
Frequently asked questions
Which primary legal sources apply?
Am I Compliant is an information and data processing service and does not provide legal advice. Results are research findings; the legal assessment and decision rest with the user.