Let us cover certain classes of individuals which may not be PEPs under strict interpretation of the existing definitions, but which one should watch carefully:

• Former Son-in-Laws of PEPs; whilst there is no longer a legal relationship, often a strong personal connection exists, especially when the former husband of the PEPs daughter has been previously involved in assisting the PEP in moving or secreting illicit funds.
• Senior officers of private corporations that are, in reality, government-controlled entities. In the developing world, government-controlled companies often appear to be privately owned. Check this carefully.
• Distant relatives whose last names are different from the PEP; they may just be closer than you think.
• Individuals who reside in, or are domiciled elsewhere. What is their status in their home country? Have you ruled out any possibility that they are PEPs at home?
• The "close associates" of relatives of known PEPs; this is a great way to move illicit funds, as most compliance officers never extend their enquiries beyond establishing that persons are relatives. Go further if any red flags appear that show that the relative moves in suspicious company.
• Forget the one-year rule on ex-PEPs; if a corrupt government figure has stolen government funds, or taken bribes, he will have that cash for quite a while after he leaves government office. I suggest a minimum of five (5) years, with a longer period if he was a top-level leader with major access.
• My best choice is the grown children of married female relatives of the PEP; they have different family names, and often do not associate with the PEP in visible way.
• Unmarried partners, whether through cohabitation, legal domestic partnerships, or civil unions registered with the local authorities. These individuals are prime candidates to covertly move illicit PEP funds of their partner, due to the high degree of trust they enjoy.

As you can see, not only are there no hard-and-fast rules on defining PEPs, but one must adjust one's personal definition to include classes of persons that a smart PEP will reach out to in laundering his illegal funds. He may be sharp; compliance needs to be sharper than the PEPs they encounter. Don't let them deceive you.