The EU's official PEP list covers 27 countries and does not name a single person

No EU authority keeps a register of politically exposed persons, so there is nothing to look a name up in. What exists is the Commission's list of the jobs that count, published in the Official Journal on 10 November 2023 as C/2023/724. Check one name in two steps: find the person's job on that list and confirm it at the official source for the job, such as a parliament's member list, EU Whoiswho or the CIA's World Leaders directory. Then match identifiers, not the name, against your file. For a sitting minister that is enough. For relatives, close associates and people who left office last year, free sources fall short.

The legal definition sits in Article 3(9) of Directive (EU) 2015/849. A politically exposed person is someone who is or has been entrusted with a prominent public function. The directive gives eight categories: heads of state and government and ministers, members of parliament, members of the governing bodies of political parties, senior judges, members of courts of auditors and central bank boards, ambassadors and high-ranking officers, members of the boards of state-owned enterprises, and the senior officials of international organisations. It excludes "middle-ranking or more junior officials" in so many words. The status is a risk category, not an accusation: the FATF calls the PEP requirements preventive, not criminal.

Article 20a then made each member state say what those categories mean at home. The result is the Commission's compiled list: a section for each of the 27 member states, including the international organisations accredited there, and one for EU institutions, taken from Commission Decision C(2022) 3105 of 20 May 2022. Members of the European Parliament and the European Commission, judges of the Court of Justice and the boards of the European Central Bank are all on it.

The national sections differ in useful ways. Austria's entry, for example, treats board members of companies in which the federal government holds at least 50 percent of the capital as PEPs, and extends that to companies controlled by a province if their annual turnover exceeds EUR 1,000,000. A national list read before the check saves a guess afterwards.

The definition will widen. Regulation (EU) 2024/1624, which applies from 10 July 2027, adds heads of regional and local authorities with at least 50,000 inhabitants, and members of the governing bodies of parties that hold seats in regional or local bodies representing at least 50,000 inhabitants. It also adds siblings to the family members of heads of state, heads of government and ministers, including deputy and assistant ministers.

The UK went the other way. Since 10 January 2024 the Money Laundering Regulations tell firms to start from the view that a domestic PEP is lower risk than a foreign one. The FCA's guidance FG25/3 was published on 7 July 2025 and revised on 15 July. It says firms should not apply the definition to UK local government, should treat only Supreme Court judges as PEPs among the judiciary, and should not treat non-executive board members of central government boards as PEPs.

Once you know which function you are checking, the official record of who holds it is usually free to search. The trouble is that each source covers one slice.

The CIA directory is narrower than its reputation. It covers heads of state and cabinet members, adds the head of each central bank, and includes ambassadors to the United States and permanent representatives to the UN in New York. Members of parliament, judges and the boards of state companies are outside its stated scope, so a no-match there settles nothing about those groups.

OpenSanctions is the closest thing to a free aggregate. It describes the task plainly: "most countries do not maintain official databases of PEPs", so it collects office-holders from parliaments and government sites one source at a time. A few countries do publish named lists; its source table includes one from Brazil's General Control Office of the Union. Its data is published under Creative Commons Attribution-NonCommercial 4.0, and its site says businesses must acquire a data licence. A compliance team screening customers is a business.

Suppose a prospective client in Vienna lists her occupation as "supervisory board, regional energy company". The steps:

1. Write down what you hold. Full name as on the identity document, date of birth, nationality, residence, and the occupation she gave you.
2. Find the function in the national list. Austria's section of C/2023/724 covers boards of companies a province controls when turnover exceeds EUR 1,000,000. A regional energy company may well qualify; its annual accounts will tell you.
3. Confirm the appointment at the source. The company's own report, the province's announcement or the commercial register should name the board. Note the appointment date and any end date.
4. Check the other categories. Search the national parliament, the government and, for cabinet-level posts, the CIA directory. Search EU Whoiswho if she claims an EU role.
5. Compare identifiers, not names. A board member with the same name and a different year of birth is a different person. The same name with no date anywhere is an open question, and your note should say so.
6. Record the result with its date. "No match in the sources checked on 1 October 2026", followed by the list of sources, is a finding. "Not a PEP" is a conclusion the sources cannot support.

Step 6 matters more than it looks. Article 20 of the directive requires risk-based procedures to determine whether a customer is a PEP. Someone who reviews your file later will want to see what you checked, not what you concluded.

The directive extends the same measures to family members and to persons known to be close associates. Family members are the spouse or equivalent partner, the children and their spouses or partners, and the parents. Close associates are people with joint beneficial ownership of a legal entity with the PEP, or another close business relationship, and people who solely own an entity set up for the PEP's benefit.

None of the official sources in the table lists them. Parliaments do not publish their members' parents, and a shared surname is not evidence of kinship. OpenSanctions notes that its basic PEP collection lacks relatives and close associates; they appear only in its enriched default dataset, tagged separately from office-holders.

The EU has defined close associates but not yet said how to identify them. Under Article 42 of the 2024 regulation, the new Anti-Money Laundering Authority must issue guidelines on the criteria by 10 July 2027. Until then, a relationship needs its own source, as our guide to reviewing a PEP or RCA match explains.

Leaving office does not end the obligation. Article 22 of the directive requires firms to keep taking the continuing risk into account for at least 12 months, and longer if the risk remains. The 2024 regulation keeps the 12-month floor.

The UK adds two details. The FCA says family members of a former PEP should be treated as ordinary customers from the moment the PEP leaves office, unless other risks justify more. It also notes that the Regulations do not allow these measures for UK office-holders who left before 26 June 2017.

This is where websites let you down. A parliament's member page shows who sits today, not who sat there last year. OpenSanctions records tenure start and end dates and marks a position as "ended" while it stays within its retention window, which is the shape of record a former-PEP check needs.

The free route works for an occasional check on a single name. It strains in four places: volume, because each name means several searches; change, because a customer can take office after you onboard them; relatives and associates; and proof, because a screenshot is a weak record of what a website said on a given day.

The FATF's guidance is blunt about the alternative. Commercial and other databases exist, it says, but "these databases are not sufficient to comply with the PEPs requirements, nor does FATF require the use of such databases". The FCA says the same for UK firms: they may use commercial databases, but must understand how they are populated and confirm that a flagged person meets the legal definition.

For teams that do want a tool, ScreenVeritAI's Quick Check runs one name against sanctions lists, PEP and RCA records and criminal watchlists in a single pass for €0.39. The snapshot of 30 September 2026 held 695,260 people classified PEP and 35,508 classified RCA, drawn from 297 contributing datasets. Each candidate shows the source references and dates its record carries, and the result is stored as a dated snapshot.

This guide describes how to find and document PEP status for one person. It does not set out which enhanced due diligence measures apply once you find it, how to establish source of wealth, or the national rules outside the EU and the UK. The function lists, the 12-month periods and the 2027 changes are quoted from the texts listed below as they stood on 1 October 2026.