Politically Exposed Persons: Who Counts Under the EU AML Regulation

You classify customers and you need a clear answer to three questions: who is a politically exposed person, how do family members and close associates enter the picture, and what additional measures follow once someone is classified? This article reads the text of the EU Anti-Money Laundering Regulation, Regulation (EU) 2024/1624, and quotes it where the wording matters.

For information; not legal advice.

When the rules apply

The Regulation was published in the Official Journal on 19 June 2024 and, according to its final provision, applies from 10 July 2027 (with a later date for certain categories of obliged entity listed in the text). This article describes the text of the Regulation.

Who is a politically exposed person

Article 2(1), point (34), defines a politically exposed person as "a natural person who is or has been entrusted with prominent public functions". The definition then lists the functions. In a Member State they include heads of State, heads of government, ministers and deputy or assistant ministers; members of parliament or similar legislative bodies; members of the governing bodies of political parties that hold seats in national executive or legislative bodies, or in regional or local bodies representing constituencies of at least 50 000 inhabitants; members of supreme courts, constitutional courts or other high-level judicial bodies whose decisions are not subject to further appeal except in exceptional circumstances; members of courts of auditors or of the boards of central banks; ambassadors, chargés d'affaires and high-ranking officers in the armed forces; members of the administrative, management or supervisory bodies of state-controlled enterprises and, for medium-sized or large undertakings, enterprises controlled by regional or local authorities; and heads of regional and local authorities with at least 50 000 inhabitants. Member States may add other prominent public functions.

The definition continues beyond the Member States. In an international organisation it covers the highest-ranking officials, their deputies and members of the board or equivalent functions, as well as representatives to a Member State or to the Union. At Union level it covers functions at the level of Union institutions and bodies that are equivalent to several of the Member State functions, and in a third country it covers functions equivalent to those listed for Member States.

Two words in the opening phrase deserve attention: "is or has been". A person who has left office is still within the definition, and Article 45 deals with what follows, as set out below.

Who maintains the list of functions

Article 43 sets up a list-based approach. Each Member State issues and keeps up to date a list indicating the exact functions that qualify as prominent public functions under its national law, and asks each international organisation officially represented on its territory to do the same. The Commission draws up the list of functions at Union level, assembles a single list of all prominent public functions from the lists provided, and publishes that single list in the Official Journal, and the Anti-Money Laundering Authority makes it publicly available on its website. The Commission may adopt delegated acts to supplement the definition where lists notified by Member States identify common additional categories.

For a compliance analyst, the practical effect is a more precise reference than a general description: the classification of a function can be checked against a published list, once the single list exists.

Family members and close associates

Article 2(1), point (35), defines a family member as a spouse or a person in a registered partnership, civil union or similar arrangement; a child and the spouse or partner of that child; a parent; and, for the functions of heads of State, heads of government, ministers and deputy or assistant ministers, and for equivalent functions at Union level or in a third country, a sibling.

Point (36) defines a person known to be a close associate as a natural person who is known to have joint beneficial ownership of legal entities or legal arrangements, or any other close business relations, with a politically exposed person, or a natural person who has sole beneficial ownership of a legal entity or legal arrangement which is known to have been set up for the de facto benefit of a politically exposed person.

The word "known" carries weight: the definition of an associate rests on what is known, which is why Article 42(2) tasks the Anti-Money Laundering Authority with issuing guidelines, by 10 July 2027, on the criteria for identification of persons known to be close associates and on the level of risk associated with particular categories of politically exposed person, family member or close associate.

What follows from classification

Article 20(1), point (g), makes it a customer due diligence measure to determine whether the customer, the beneficial owner and, where relevant, the person on whose behalf a transaction is carried out is a politically exposed person, a family member or a person known to be a close associate.

Article 42(1) then requires three measures with respect to occasional transactions or business relationships with politically exposed persons, in addition to the standard measures of Article 20: obtaining senior management approval for carrying out the transactions or for establishing or continuing the relationship; taking adequate measures to establish the source of wealth and source of funds involved; and conducting enhanced, ongoing monitoring of the relationship.

Article 46 extends the measures of Articles 42, 44 and 45 to family members and persons known to be close associates. Article 44 deals with beneficiaries of life or other investment-related insurance policies: reasonable measures to determine whether the beneficiary, or the beneficial owner of the beneficiary, is a politically exposed person, taken no later than the time of the payout or the assignment of the policy.

After the function ends

Article 45(1) requires obliged entities to take into account the continuing risk posed by a person who is no longer entrusted with a prominent public function, because of the former function, in their risk assessment. Article 45(2) requires one or more of the enhanced measures of Article 34(4) to be applied until the risks no longer exist, "but in any case for not less than 12 months following the time when the individual ceased to be entrusted with a prominent public function".

The United Kingdom

For firms overseen by the United Kingdom's Financial Conduct Authority, the regulator published finalised guidance on the treatment of politically exposed persons in July 2017 (FG17/6). Its page says the guidance expects firms to take appropriate but proportionate measures and clarifies how the definitions of a politically exposed person in the UK money laundering regulations should be applied, and that it applies only to business relationships undertaken in the course of business in the UK. The page was published in 2017; check the regulator's site for the current version before relying on it.

A short classification workflow

1. Screen the customer and the beneficial owners against a source that covers politically exposed persons, family members and close associates.
2. Record which function triggered the match, in which jurisdiction, and whether the function is current or former.
3. Where the match is a family member or an associate, record the relationship and how it is known.
4. Apply and document the measures for the case: approval, source of wealth and funds, enhanced monitoring.
5. Diary the end of the minimum period for former functions and review then.

How NeuroVision fits

NeuroVision's international AML screening covers PEP checks that include relatives and associates, as part of a package with sanctions and adverse media. Politically exposed persons are returned in tiers, from tier one to tier four, with relatives and close associates.

To see how a screening result looks in your scenario, contact the team.

Sources

All sources were fetched on 27 October 2026.

• Regulation (EU) 2024/1624 on the prevention of the use of the financial system for the purposes of money laundering or terrorist financing, Official Journal text, European Union. The text was retrieved from the Publications Office of the European Union.
• FG17/6: The treatment of politically exposed persons for anti-money laundering purposes, Financial Conduct Authority, United Kingdom.