Breakdown of Politically Exposed Person (PEP) Classes

Last updated: February 27, 2026

Who is a PEP ?

A Politically Exposed Person (PEP) is someone who holds (or has held) a prominent public position that may expose them to higher corruption or bribery risk.


Breakdown of the PEP Classes

PEP Class 1 – Highest Risk (National Leadership)

Examples:

  • Heads of State / Presidents

  • Prime Ministers

  • National Ministers

  • Members of National Parliament

  • Cabinet-level officials

Why high risk?
They control:

  • National budgets

  • Defence

  • Policy decisions

  • Large public procurement

This is the highest level of political exposure.


PEP Class 2 – Regional / State-Level Government

Examples:

  • Governors

  • Members of State or Regional Parliament

  • Regional Ministers

Why medium-high risk?
They control:

  • State budgets

  • Regional development funds

  • Local public contracts

Less exposure than national leaders, but still significant.


PEP Class 3 – State-Owned Enterprise (SOE) Leadership

Examples:

  • Board members of government-owned companies

  • CEOs of state-owned banks

  • Senior management in SOEs

Why included?
SOEs often:

  • Control large public funds

  • Operate in sensitive sectors (energy, telecom, banking)

Risk relates to commercial corruption, not direct legislative power.


PEP Class 4 – Local Government Officials

Examples:

  • Mayors

  • City council members

  • Municipal officials

Why lower risk?
They manage:

  • Local budgets

  • Municipal contracts

Exposure exists but is generally lower than national or regional positions.