Determining whether you are a Politically Exposed Person

If you are unsure whether you would be classified as a Politically Exposed Person (‘PEP’) please review the below guidance carefully before submitting your details

You will be considered a PEP if you or any member of your immediate family or a close business associate have held a political or governmental position or been associated with a Prominent Person who is or has been entrusted with a prominent public function by an international organisation. Members of your family include your immediate family, as well as parents-in-law, grandchildren and partner (where that partner would be seen as the equivalent of your spouse under the laws of your home jurisdiction).

Guidance Note

1. (a) The term PEP means “Politically Exposed Person”, and includes their “Immediate Family Members” and “Close Associates” or a “Prominent Person”.

2. (b) A Politically Exposed Person means a person who is an individual who is or has been entrusted with a prominent public function, including but not limited to:

• Heads of state, heads of government, senior politicians; senior government, judicial or military officials; senior executives of state owned corporations; and important political party officials.
• An Immediate Family Member includes any of the following: a spouse; a partner, that is someone considered by his or her national law as equivalent or broadly equivalent to a spouse; children and their spouses or partners (as defined above); parents, grandparents and grandchildren and siblings.
• A Close Associate of a PEP includes any person who is known to maintain a close business relationship with the PEP, including a person who is in a position to conduct substantial financial transactions on behalf of the PEP.
• A Prominent Person means a person who is an individual who is or has been entrusted with a prominent public function by an international organisation.

If you, or your network as defined above, fall into one of these definitions, please provide us with details of:

• Who held the position, and their relationship to you;
• The position held;
• The country or jurisdictions in which the position was held;
• The dates the position was held, including if the role is ongoing.

If you are still unsure how to answer, please contact our team at compliance-enquires@floww.io