What is a Politically Exposed Person (PEP)

The Criminal Justice (Money Laundering and Terrorist Financing) Act 2010, as amended, places legal and regulatory obligations on a wide range of financial institutions, including banks, building societies, credit unions and An Post to take certain measures in regards to Politically Exposed Persons (PEPs).

The Act defines PEPs, specifies when firms must apply enhanced customer due diligence measures, and also requires firms to apply enhanced monitoring of the business relationship with PEPs. These requirements are important and are designed to protect customers and the wider financial system from abuse.

As outlined in the Act, we are required to establish whether or not a customer is a PEP, an immediate family member of, or a close associate of a PEP. The Act, as amended, transposes in a manner consistent with the approach across the EU in combating corruption, money laundering and the financing of terrorism, the requirements of the EU Money Laundering Directives including Directive 2015/849 which states that “The requirements relating to PEPs are of a preventive and not criminal nature, and should not be interpreted as stigmatising politically exposed persons as being involved in criminal activity.” Instead they recognise that holders of such roles are faced with increased exposure to risks due to the potential influence they can exercise.

A PEP is defined in the Act as an individual who is, or has at any time in the preceding 12 months been, entrusted with a prominent public function and includes holders of the following roles:

  1. a head of state, head of government, government minister or deputy or assistant government minister;
  2. a member of a parliament;
  3. a member of the governing body of a political party;
  4. a member of a supreme court, constitutional court or other high level judicial body whose decisions, other than in exceptional circumstances, are not subject to further appeal;
  5. a member of a court of auditors or of the board of a central bank;
  6. an ambassador, chargé d ’affairs or high-ranking officer in the armed forces;
  7. a director, deputy director or member of the board of, or person performing the equivalent function in relation to, an international organisation;
  8. a member of the administrative, management or supervisory body of a state-owned enterprise.

If you meet the definition of a PEP, we are required to gather additional information and documentation relating to your funds and wealth e.g. a statement of assets and, where required, to hold up to date copies of your name and address documents.

The fact that we ask for confirmation of your status as a PEP and / or documentation is driven by our legal obligations and is in no way a reflection on the operation of your accounts with Bank of Ireland.