When we consider the traditional definition of PEPs, we usually mean the folllowing :

• Senior military officer: Army and Air Force Colonel/Navy Captain or above, meaning general officer or flag rank.
  

• Senior governmental official:heads of major governmental departments or agencies, ministers, congressmen or senators, or high-ranking functionaries.

• Senior officials of non-governmental organisations: individuals with leadership, titles and authority over rank-and-file staff. They also have the ability to bind the NGO through contract, and to approve and fund budgetary items.
  

• Leaders of charitable entities: very senior staff, who set, and implement, policy and strategies, and who decide how contributions are spent.
  

• Directors and senior officers of non-profit companies:  Individuals who set corporate agendas and goals, and have discretionary and budgetary spending authority.
  

Now that we know what fits inside the envelope, let us travel outside, into the realm of non-PEPs that I  consider to be the functional equivalent of Politically Exposed Persons, even though you may disagree on technical grounds:

• Government attorneys who are counsel to their ministry, agency or department.

• Senior secretaries or administrative assistants to high-ranking governmental officials.

• Unpaid outside advisers to NGO or non-profit corporations.

• Outside Directors and influential committee members of major charities.

• Army and Air Force Majors, and Navy Lieutenant Commanders who are involved in purchasing or contracting.

• Aides to general officers or flag rank officers (admirals or commodores).

• Contract officers at non-governmental organisations.
  

All of the above have either opportunity to illegally acquire governmental funds or assets, or could be bribed to aid and abet a specific government contract, or could facilitate a contract with an NGO or nonprofit. For these reasons, we must consider these intermediate positions quasi-PEP, meaning that, whilst they do not fit the pure definition of PEP, we must treat them as Politically Exposed Persons as part of risk management.

Note: Alternatively, real PEPs may use these non-PEPs as fronts to move their illicit cash, first constructing some sort of bogus Source of Funds origin, like inheritance, family wealth, lottery winnings, or some other plausible source of income. Genuine verification enquiries will look right through these contrived sources.
 
Source of Funds becomes a paramount consideration in deciding whether to accept the business of quasi-PEPs, just as it is with the true PEPs. Do not take short-cuts here; if they are even borderline
with any of the above categories, investigate before approving them for any new account relationship.