PEP Tiers

PEP tiers

PEPs are categorised into 3 different tiers depending on their level of risk exposure:

PEP Tier 1 Represents:

• Head of state and their deputies
• Head and members of government (national level in unitary states; sub-federal/state level in federations; supranational level European Commission, Europe Council) and their deputies
• Heads and top commanders of the armed forces - armed forces joint command members, commanders of the main branches of the armed forces
• Members of the legislature (national level in unitary states; sub-federal/state level in federations; supranational level European Parliament)
• Heads and members of last-instance courts (supreme, constitutional, high, European Court of Justice, specialised courts)
• Heads and members of central banks and court of auditors (national level in unitary states; sub-federal/state level in federations; supranational level European Court of Auditors)
• Party leaders and executive council members (Parties represented in the national parliament of unitary states and in the federal and sub-federal parliaments in federations)


PEP Tier 2 Represents:

• Senior diplomats (ambassadors, high-commissioners, charge d'affaires, permanent representatives)
• Heads and board members of the executive bodies of international organisations established by treaty (the highest governing bodies of ARI list of organisations)
• Members of the board of directors of SOEs, top executives (C-level)
• Senior officials (e.g. high-ranking civil servants, director generals, directors, heads of units) of agencies and boards appointed by the head of state, the government (cabinet and ministries) and the parliament
• Members of executive (e.g. governor, prefect) bodies at sub-national level in unitary states and below sub-federal level in federal jurisdictions
• Members of legislative (e.g. aldermen, councillors) bodies at sub-national level in unitary states and below sub-federal level in federal jurisdictions
• Mayor of capital city and large municipalities (megapolis)
• Judges, justices, magistrates, prosecutors, attorneys in courts with jurisdiction at sub-national level in unitary states and below the sub-federal level in federations
• Commanders of major national military units (battalions, brigades, flotillas, bases)


PEP Tier 3 Represents:

• Middle ranking diplomats (minister-counsellors, councillors, 1st Secretaries and 2nd Secretaries) and low-ranking diplomats (attaché)
• Mayor, council member and senior officials of medium to small municipality.

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