From the very earliest days of World-Check, I recall much industry discussion on PEPs, the risk of doing business with them and the lack of an internationally accepted definition. There were even calls post the introduction of PEP requirements for regulatory authorities to produce PEP lists. Whether it was thanks to General Abacha or to the Riggs Bank scandal, the financial community has come to accept PEP-checking is here to stay. This discussion paper serves to provide an opinion on how we could perhaps better address certain PEP issues and how this subject may need to evolve.

The aim of this paper is to make a meaningful contribution to the existing body of knowledge about Politically Exposed Persons, or PEPs, for short. In refining and expanding the scope of the existing PEP definition, this paper will explore the operational implications of dealing with this heightened-risk category.