Banks, insurance companies, leasing firms, gambling operators, lawyers, real estate agencies, consultancy firms, and payment institutions are just some examples of entities required by law to identify politically exposed persons (PEPs).
These entities must monitor transactions to make sure they are not unusual or suspicious (e.g. money originating from criminal activities such as corruption).
The required monitoring now extends beyond domestic clients to include individuals holding significant public roles within the European Union (EU). That means that entities such as banks or gambling operators must not only check domestic officials but also those holding key positions within specified EU institutions.
The European Commission recently published a consolidated list of significant public functions endorsed by financial intelligence units across EU member states responsible for preventing and combating money laundering. This list contains specific public roles within EU institutions and bodies.
Introducing the EU-Level Politically Exposed Persons Database
HitHorizons has built a database of EU-Level Politically Exposed Persons (PEPs) holding significant roles within the EU. Obligated entities can access this database in two ways:
- Web Interface: Manual searches and verification through our web interface are ideal for quick checks of individual profiles or one-time detailed screenings.
- API Integration: Direct and automated access to our PEPs database from any software ecosystem simplifies compliance screening for organisations that need to perform a significant number of verifications.
Database Coverage and Data Sources
The database currently includes over 1,300 EU officials who have held significant public functions in the past 12 months. Additionally, it identifies more than 400 related individuals, such as spouses, partners, children, sons-in-law, daughters-in-law, and parents of primary PEPs.
Categories of Politically Exposed Persons
Obligated entities must apply heightened diligence for at least one year after a PEP leaves office, extending to five years for those with ongoing risks. PEPs with persistent risks (mainly key officials within EU institutions and those who held long-term significant public functions) are archived in the EU-Level PEPs Database for up to five years after the end of the function or elected mandate.
HitHorizons uses a wide range of publicly available sources to make sure that obligated entities can access the most current and accurate information. These sources include official government publications, financial intelligence units, and public records. The database is manually curated and continuously updated to track new appointments and role changes.
Predominant Categories in the Database
According to our database, as of June 2024, the largest group of EU-Level PEPs are Members of the European Parliament (MEPs), making up nearly half of the primary PEPs, and diplomats from non-EU countries accredited to the EU.
The database includes four other critical categories of EU officials besides MEPs and diplomats: European Commissioners, Judges of the Court of Justice of the EU, Members of the European Court of Auditors, and Officials of the European Central Bank.
Shares of PEP Categories at EU Institutions
Diverse Representation Across Member States
The five largest EU members (Germany, France, Italy, Spain, and Poland) constitute over one-third of the database, with the remaining 22 member states accounting for around 44%. Approximately 6% of primary PEPs are from non-EU countries (mainly ambassadors and diplomats accredited to the EU).
Primary PEPs by Identified Domicile
Ensuring Compliance and Mitigating Risks
With the EU-Level PEPs Database, obligated entities can efficiently identify and verify PEPs, conduct thorough checks, and enhance their compliance processes. The ongoing updates and detailed insights offered by the HitHorizons EU-Level PEPs Database make sure that obligated entities can always rely on up-to-date data.
