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.