4.6.4.3. PEP Tiers

Within the PEP, Sanctions, Adverse Media tab, you can find not only if a person is a Politically Exposed, but also, generally speaking, to what degree. The PEPs are divided into “tiers”, which, as a “rule of thumb”, the lower the number of the tier, the higher the person’s political exposure.

The below lists depict the basic logic behind the tiers. However, as not all terms have the same meaning in every jurisdiction, variations may occur. Note also that the tier system may change from time to time, and is also a mere tool which provides a quick overview of the PEP, but it is not a substitute for an in-depth examination of the PEP status of each checked person.

Also note that in some cases, a PEP tier will not show, even though the person is a PEP. Reasons for this vary, and depend mostly upon the availability of relevant data.

PEP Tier 1

Position	Examples
Executive Branch - Head of State and Deputy	Head of state and their deputies
Executive Branch - Head and Members of Government and Deputies	Head and members of government (national level in unitary states; sub- federal/state level in federations; supranational level European Commission, Europe Council) and their deputies
Executive Branch - Professional and Ceremonial Heads of the Armed Forces	Heads and top commanders of the armed forces - armed forces joint command members, commanders of the main branches of the armed forces
Legislative Branch - Parliaments	Members of the legislature (national level in unitary states; sub- federal/state level in federations; supranational level European Parliament)
Judicial Branch - Last- Instance Courts	Heads and members of last-instance courts (supreme, constitutional, high, specialised courts, European Court of Justice)
Central Bank and Court of Auditors	Heads and members of Central Bank and Court of Auditors (national level in unitary states; sub-federal/state level in federations; supranational level EU Court of Auditors)
Parliamentary Political Party Leaders	Party leaders and executive council members [parties represented in the national parliament of unitary states and in the federal and sub-federal parliaments in federations]

PEP Tier 2

Position	Examples
Executive Branch - Senior Diplomats	Senior diplomats (ambassadors, high-commissioners, charge d'affaires, permanent representatives)
Executive Branch - International Organisations	Heads and board members of the executive bodies of international organisations established by treaty (ARI list of organisations)
Executive Branch - SOE Directors	Members of board of directors of SOEs, top executives (C-level)
Executive branch - Law Enforcement and Regulatory Agencies	Senior officials (e.g. high-ranking civil servants, director generals, directors, heads of units) of agencies and boards appointed by the Head of State, the Government (Cabinet and Ministries) and the Parliament
Executive branch - Regional Governments	Members of executive (e.g. governor, prefect) bodies at sub-national level in unitary states and below sub-federal level in federal jurisdictions
Executive Branch - Regional Legislatures	Members of legislative (e.g. aldermen, councillors) bodies at sub- national level in unitary states and below sub-federal level in federal jurisdictions
Executive branch - Local Governments	Mayor of capital cities and large municipalities (megapolis) [scope to be determined based on the population of the country]
Judicial Branch - District and Regional Courts and Prosecutions	Judges, justices, magistrates, prosecutors, attorneys in courts with jurisdiction at sub-national level in unitary states and below the sub- federal level in federations
Executive Branch - Commanders of the Armed Forces	Commanders of major national military units (battalions, brigades, flotillas, bases)

PEP Tier 3

Position	Examples
Executive Branch - Middle and Low-Ranking Diplomats	Middle ranking diplomats (minister-counsellors, councillors, 1st secretaries and 2nd secretaries) and low-ranking diplomats (attaché)
Executive branch - Local Governments	Mayor, council member and senior officials of medium to small municipality [scope to be determined based on the population of the country]

PEP by Association

Also note, that there are “PEPs by Association”. These will be relatives and close associates (RCAs) of PEPs. For example:

Closely related family members of PEPs - parents, spouses / civil partners, children, siblings.
Extended family members of PEPs: daughter and son-in-law, co-parents-in-law, second-degree relatives such as grandchildren or cousins. May vary across jurisdictions.
Close associates of PEPs: Individuals explicitly mentioned as "close associate" of a PEP; business partners (defined as joint shareholders in private companies and persons, who are reported as owners of businesses and other assets set up for the benefit of a PEP); “gatekeeper” services providers (such as lawyers, notaries, accountants, investment advisors, trust and company service providers who assist in transactions involving the movement of money or, as defined by the Wolfsberg Group - persons acting in a financial fiduciary capacity). Employers and employees of PEPs could be also considered close associates depending on the time of the association, the seniority of the appointment, and its proximity to the PEP.