Is There an Official PEP List? How to Search for PEPs

The FATF's 2013 guidance on PEPs does not discuss a global list, but it does address government lists. Under "Government issued PEP-lists", it says countries sometimes publish lists of domestic PEPs or prominent public functions, "although this is not required by the FATF standards" (para 64). It separates two types:

• Lists of names. FATF does not advocate these. It says they "are quickly outdated, difficult to manage, costly to maintain, and do not contain family members or close associates", and that firms may come to rely on them exclusively (para 65).
• Lists of positions or functions. FATF sees these as "an important source of information", because what counts as a prominent function depends on how each government is organised (para 66).

FATF adds the point that matters most in practice: inclusion on a list can confirm that someone is a PEP, but absence does not rule it out (para 64). Definitions also differ. Regulation (EU) 2024/1624, which applies from 10 July 2027 for most obliged entities, uses a threshold of at least 50 000 inhabitants for some regional and local roles, the FCA gives its own view of which UK roles count, and US BSA/AML regulations do not define the term at all. In our view, a single list would have to choose between these definitions or reconcile them.

Write down which rules bind you, which roles you treat as prominent, and whom you check: investors, beneficial owners, controllers, and, in Singapore, persons acting for the customer and connected parties. In our view, a list search with no definition behind it is hard to defend. Definitions differ: Hong Kong's statutory PEP definition covers only functions outside Hong Kong, though the SFC still asks firms to take a risk-based approach to Hong Kong and international organisation PEPs (4.11.4). FCA guidance for the firms it supervises excludes UK local government (FG17/6, 2.16). MAS Guidelines for capital markets intermediaries say Singapore domestic PEPs should include at least all Government Ministers, Members of Parliament, Nominated Members of Parliament and Non-Constituency Members of Parliament (8-4-2).

FATF calls the customer "a valuable source of information" (para 56). Collect occupation, employer and any public role in your form, and ask about senior public roles held by close family. Do not rely solely on a tick-box declaration: FATF says relying on self-declarations alone shifts the firm's obligation to the customer, that the answer may be false, and that many customers could not tell whether they are a PEP (para 77).

Where the person's role looks public, confirm it against the relevant government or parliament site, and use a list of functions to decide whether that office qualifies. For the EU this means OJ C/2023/724. For others, look for the regulator's guidance, such as FCA FG17/6 paragraph 2.16 or MAS Guidelines 8-4-2.

Search a database by full name, aliases, date of birth and nationality. If you are using a vendor, the FCA expects the firms it supervises to understand how its data is populated and to make sure that flagged people fit the legal definition (FG17/6, 2.11). A clear result is not proof of absence: FATF warns against assuming that a name not in a database means the client is not a PEP (para 62).

Search the name with the role, the country and the local-language spelling. In our view, this helps most where the investor comes from a place with thin official sources, or where a family link is the likely connection. Record the terms used and the date.

Compare date of birth, nationality, known addresses and career history. Record whether the person is a PEP, family member, close associate or a false match, who decided, and on what evidence. Under-classification brings higher risk and over-classification an unnecessary burden, as the SFC notes (4.11.3).

Apply the measures in your regime: usually senior management approval, source of wealth and funds, and enhanced monitoring. Then repeat the checks. FATF notes that existing clients sometimes become PEPs and that firms should monitor for a change in status (para 58). No single frequency applies across these regimes, but some texts set markers. The SFC says customers presenting high risks should have at least an annual review (5.3), and MAS Notice SFA04-N02 requires screening at onboarding, periodically and when the persons connected to the customer change (6.40). Tie your frequency to risk and record the reason.

The search leads to a risk decision, and the measures differ by regime. The table summarises the texts; see each source for conditions.

US advisers. FinCEN's investment adviser rule (89 FR 72156) does not take effect until 1 January 2028 under the delay rule (91 FR 36). In its preamble, FinCEN acknowledges that private fund advisers may perform sanctions or PEP screening as part of investor diligence, and says such efforts are only one part of effective AML/CFT compliance.

• Treating a sanctions list as a PEP list. OFAC's SDN list and similar lists name people subject to sanctions. Being a PEP is a risk category, and the SFC says the status "does not automatically mean that the individuals are corrupt" (4.11.1).
• Treating "no hit" as a conclusion. FATF warns that neither a hit nor a clear result settles the question (para 62).
• Screening investors but not owners. The FATF, Singapore, Hong Kong, UK and Cayman texts above all reach beneficial owners as well as customers.
• Forgetting family and associates. They "might never be listed, but are still to be treated as PEPs" (FATF, para 68), so ownership links and customer conversations matter.
• Using one global definition without checking it. A vendor's category may be wider or narrower than your rule. The FCA, for example, tells the firms it supervises to treat only Supreme Court judges among the UK judiciary as PEPs (FG17/6, 2.16).
• Applying one risk score to all PEPs. Regimes differ on domestic and former PEPs. Risk should be documented, not assumed.