A bank questionnaire asking whether the customer is a politically exposed person leaves many people equally puzzled: it’s unclear exactly what’s being asked and who even falls into this category. The confusion is compounded by the fact that the law barely uses a collective term at all: 115-FZ describes three categories of persons in detail and defines a common concept for them only once — in Article 7.1 — while the familiar Russian abbreviation PDL is taken from the translation of an international standard.
This isn’t just a question for the customer who received the questionnaire: for the organizations themselves that are required to identify such persons under 115-FZ, the exact classification determines which measures to apply and to what extent.
Below: what PEP status actually means, how it relates to the Russian abbreviation PDL, and why “politically significant person” is not a legal term, what requirements the law imposes on different categories of such persons, and what to do if a customer check turns up a match.
Who Counts as a Politically Exposed Person
The international standard on combating money laundering — the FATF Recommendations — describes a politically exposed person through a single characteristic: the significance of the public functions involved, not the mere fact of working in a government body.
The FATF Definition and What “Prominent Public Functions” Means
The definition is given in the General Glossary of the FATF Recommendations; quotations from the standard in this article follow the FATF Recommendations’ own English text.
Foreign PEPs are “individuals who are or have been entrusted with prominent public functions by a foreign country, for example Heads of State or of government, senior politicians, senior government, judicial or military officials, senior executives of state owned corporations, important political party officials.” Domestic PEPs are defined the same way, but with reference to functions within the country. Persons entrusted with an important function by an international organization are members of senior management — directors, deputy directors, and members of the board, or equivalent positions.
Historically, FATF introduced mandatory requirements for foreign PEPs in June 2003, and in February 2012 extended them to domestic PEPs and international-organization PEPs — in line with Article 52 of the United Nations Convention against Corruption.
Why Not Every Official Falls Into This Category
The definition is explicitly limited in scope by seniority. The General Glossary of the FATF Recommendations closes with exactly that caveat: it excludes middle-ranking officials and persons in lower positions within the listed categories. The criterion is not the mere fact of working in a government body, but the significance of the public functions involved: a rank-and-file department employee or a regional specialist generally does not fall into the category.
PDL, PEP, “Politically Significant Person”: Which of These Is a Legal Term
Article 7.3 of 115-FZ describes the three categories of persons in detail, without a collective term, and the abbreviation “PDL” does not appear in it. But the phrase “publicly exposed persons” itself does appear in the law — in Article 7.1, which is addressed to lawyers, notaries, auditors, persons providing legal and accounting services, and a number of other “other persons.” There, in paragraph 7, the law states directly that the publicly exposed persons referred to in paragraph 1 of that article mean the persons listed in Article 7.3(1)(1) — that is, all three categories at once. The law gives no separate definition in Article 3, “Basic Concepts.” The abbreviation “PDL,” on the other hand, comes from the Russian translation of the FATF Recommendations, where that is the name given to Recommendation 12 itself, and where the abbreviation is introduced. PEP (Politically Exposed Person) is the same concept in English — the standard’s own term.
Neither 115-FZ nor the Russian translation of the FATF Recommendations uses the term “politically significant person” (“политически значимое лицо”). The industry shorthand abbreviations IPDL (foreign publicly exposed person), RPDL, and DLPMO (official of a public international organization) don’t appear in the law either — they’re convenience abbreviations that only work if spelled out at first use.
Who Is a Politically Exposed Person: Three Categories Under 115-FZ and Three Regimes
Article 7.3 of 115-FZ describes three categories of persons. The obligation to identify them applies equally to all three, but the requirements diverge from there — and that’s the main point people usually miss.
| Category | Who It Covers | How Status Is Determined | Screening Specifics |
|---|---|---|---|
| Foreign politically exposed persons | Heads of state and government, senior politicians, senior government, judicial, and military officials, senior executives of state-owned corporations of other countries | Status is determined in accordance with the FATF Recommendations | Full set of requirements: a written decision to accept the customer for service, establishing the source of funds, regularly updating information, and heightened attention to transactions |
| Officials of public international organizations | Members of senior management of international organizations — directors, deputy directors, members of the board, or equivalent positions | Status is determined in accordance with the FATF Recommendations | Requirements apply only if the customer has been assigned a high risk level |
| Persons holding Russian positions listed in Article 7.3 | State positions of the Russian Federation; positions of members of the Bank of Russia’s Board of Directors; federal civil-service positions to which appointment and removal is carried out by the President or the Government of the Russian Federation; positions at the Bank of Russia, state corporations, and other organizations created by the Russian Federation under federal laws — included in lists of positions determined by the President of the Russian Federation | There’s no single list for the whole category: state positions of the Russian Federation follow the President’s consolidated list; members of the Bank of Russia’s Board of Directors follow the information on the Bank of Russia’s website; the organization determines the remaining groups itself, based on current legislation | Requirements apply only if the customer has been assigned a high risk level |
What this looks like with specific examples:
| Example | Category | Comment |
|---|---|---|
| A minister of a foreign country | Foreign politically exposed person | Measures apply unconditionally, without the high-risk condition |
| A director, deputy director, or board member of an international organization | Official of a public international organization | Measures apply only when a high risk level is assigned |
| A State Duma deputy | Russian category; the position is directly named on the consolidated list of state positions | Measures apply only when a high risk level is assigned |
The reverse rule doesn’t hold: you can’t conclude that a given official is not a politically exposed person based on seniority alone. The FATF definition does exclude middle-ranking officials and persons in lower positions, but for the Russian category, the decisive criterion is whether the position appears on the relevant list, regardless of its seniority.
Regional and municipal-level deputies are a separate case. A regional or municipal deputy’s mandate alone is not enough for Article 7.3: such a deputy holds a state position of a constituent entity of the Russian Federation or a municipal position, while the article refers to state positions of the Russian Federation itself.
FATF’s approach is broader here — it explicitly states that prominent public functions also occur at the regional and municipal level. But this doesn’t affect the composition of the Article 7.3 categories: the law refers to the FATF Recommendations only for foreign officials and officials of international organizations, while the Russian category is defined by lists of positions.
What the organization can actually do is factor that status into the customer’s risk assessment under its own internal control rules. And separately: if the same person simultaneously holds a position that is on the presidential list, they fall into the category — but on the basis of that position, not the mandate.
Foreign Politically Exposed Persons: The Full Set of Requirements
For this category, the law states its requirements directly and unconditionally. A foreign politically exposed person may be accepted for service only on the basis of a written decision by the head of the organization, their deputy, or the head of a separate division with delegated authority. The organization is required to take reasonable and available measures to establish the source of such persons’ funds or other property, update information about them on a regular basis, and pay heightened attention to transactions they carry out themselves or on whose behalf they are carried out.
Officials of International Organizations and Russian Officials: Only at a High Risk Level
For the other two categories, these same requirements don’t apply by default. Article 7.3(3) sets out the condition as follows: if an organization carrying out transactions with funds or other property has assigned a high degree (level) of suspicious-transaction risk to the financial transactions of a customer who is an official of a public international organization or a person holding (occupying) a state position of the Russian Federation, the requirements established by subparagraphs 2–5 of paragraph 1 of that article apply to that customer’s financial transactions.
This means the relationship between PEP status and risk level works differently than is usually assumed: it’s not that the status makes the customer high-risk, but that the high risk level assigned by the organization is what triggers the full set of requirements for these two categories. Assigning a risk level is a separate obligation under Article 7 and a matter of the specific organization’s internal control rules.
How Status Is Determined and Where the Lists of Positions Come From
Article 7.3(4) establishes that whether a person belongs to the category of foreign politically exposed persons or officials of public international organizations is determined in accordance with the recommendations of the Financial Action Task Force (FATF).
Paragraph 4 does not mention the Russian category: for it, Article 7.3 establishes its own circle of positions, and that circle is structured unevenly. State positions of the Russian Federation are listed in the consolidated list approved by Presidential Decree No. 974 of 14 November 2024, “On State Positions of the Russian Federation” — for this group, the list is exhaustive. But the decree was not adopted for the purposes of 115-FZ and does not cover the whole circle of persons under Article 7.3: members of the Bank of Russia’s Board of Directors are not on the consolidated list at all — only the Governor of the Bank of Russia is — which is exactly why the law names them as a separate group. Information about them is published on the Bank of Russia’s official website.
The organization determines the remaining groups itself — federal civil-service positions to which appointment and removal is carried out by the President or the Government, and positions at the Bank of Russia, state corporations, and other organizations created by the Russian Federation under federal laws. In its methodological recommendations — issued under Information Letter No. 53 of 12 December 2017 — Rosfinmonitoring (the Federal Financial Monitoring Service) notes that primary financial monitoring entities independently track current legislation to determine the circle of such positions. This is an independent determination of the circle of positions, not a check against a ready-made list: what matters here is the criterion set by the relevant provision or presence on the relevant list — the person’s actual workplace is not significant on its own. That’s why questionnaires ask directly whether the customer holds a position within this circle.
There’s a narrow exception to this rule. Credit institutions and branches of foreign banks don’t apply the requirements of Article 7.3(1) when a natural person exchanges cash currency for an amount up to ₽40,000, or when a natural person orders a transfer without opening an account for an amount up to ₽15,000 (or the equivalent in foreign currency). The exception doesn’t apply if staff develop suspicions that the transaction is being carried out for the purposes of money laundering or terrorist financing. This relief doesn’t extend to the other organizations covered by 115-FZ. A separate article covers in detail who 115-FZ applies to in general and which organizations are required to identify such customers.
Do Family Members Fall Under the Check
The list of relatives the law names alongside a foreign PEP is closed, and it covers spouses; close relatives in the direct ascending and descending line (parents and children, grandparents and grandchildren); full and half siblings (siblings sharing a common father or mother); and adoptive parents and adopted children.
Relatives are named in the text of the law itself only in relation to foreign politically exposed persons — in Article 7.3(1)(5), which deals with heightened attention to their transactions. For the other two categories, the law does this by reference: if the organization has assigned the customer a high degree (level) of risk, subparagraphs 2–5 of paragraph 1 apply to that customer’s financial transactions — and among them is the one addressing spouses and close relatives. The Russian Ministry of Finance, in Information Message No. IS-uchet-17 of 12 April 2019, reads this reference exactly that way: at a high risk level, heightened attention also extends to the transactions of that customer’s spouse and close relatives.
Establishing the connection to the official in the first place is a separate task. For banks, this isn’t just practice: Bank of Russia Regulation No. 499-P of 15 October 2015 directly includes among the information to be established the customer’s position, if they belong to the persons under Article 7.3(1)(1), and the degree of kinship or spousal status in relation to such a person. This is a stage of identification, and it doesn’t depend on the assigned risk level. For the other organizations covered by 115-FZ, the law doesn’t prescribe a form: a question in the questionnaire that the customer fills in themselves is the method recommended in Rosfinmonitoring’s methodological recommendations, and in practice it’s exactly this method that is used.
One separate thing worth keeping in mind: the concept of “close associates” doesn’t exist in 115-FZ at all — the FATF standard’s close associates category cannot be carried over into a description of the law’s requirements.
FATF’s Recommendation 12 is formulated more broadly: it extends these requirements to family members and persons close to any type of PEP. The difference is twofold — for FATF, this applies to all types of PEP, not just foreign ones, and it covers not only relatives but close associates as well. That said, a relative doesn’t acquire PEP status on their own account — they merely inherit the heightened-attention regime for as long as the official themselves retains the status. An illustration from the 2013 FATF Guidance makes the logic clear: a foreign president’s newborn son doesn’t become a PEP in his own right (unless he is heir to the throne or succeeds his father in that position), but the same attention regime applies to transactions connected with him for as long as his father holds the office.
Why a Bank Asks the Customer About Politically Exposed Person Status
The question about PEP status is one of the most common items on questionnaires used by banks and other organizations required to identify such customers. The wording usually mirrors the law: the question isn’t about the customer’s occupation in an everyday sense, but about whether the position the customer currently or previously held falls into one of the three categories described above.
For the customer who receives such a questionnaire, the answer isn’t a cause for concern but a formal basis on which the organization will build its further checks. If the position falls into one of the categories, the corresponding regime then applies — from a written decision to accept the customer for service for foreign PEPs, to applying the requirements only once a high risk level has been assigned for the other two categories. The organization asks the same question about the customer’s beneficial owner as well: if a company has an ultimate beneficial owner, that person is also checked for PEP status — separately from checking the customer itself, as part of broader counterparty due diligence.
What Changes for a Customer With PEP Status
Confirmed status triggers specific measures. For a foreign PEP, that means a written decision by an authorized person to accept the customer for service, establishing the source of funds, regularly updating information, and heightened attention to transactions. For an official of an international organization or a person holding a Russian position from the circle established by Article 7.3, the same measures kick in only once the organization has assigned the customer a high risk level.
The requirements are preventive, not criminal, in nature, and don’t mean that a person with PEP status is somehow connected to criminal activity: refusing a business relationship solely because the customer is a politically exposed person is contrary to the letter and spirit of Recommendation 12.
In its methodological recommendations — issued under Information Letter No. 53 of 12 December 2017 and addressed to organizations not supervised by the Bank of Russia — Rosfinmonitoring recommends the same thing: refusing to accept a customer for service solely because they fall into the PEP category is not permitted. This doesn’t override the independent grounds for refusal that the law itself provides: if identification could not be completed, the organization is required to refuse to accept the customer for service, and if there are suspicions of money laundering, it is entitled to refuse to carry out the transaction — the customer’s status has nothing to do with it in either case.
A match on one or two heightened-risk indicators doesn’t by itself amount to suspicion — several indicators need to line up for that, and the list of indicators is aimed at identifying those who abuse the financial system, not at stigmatizing all PEPs.
How to Check a Customer for PEP Status
The law sets out obligations, not a step-by-step algorithm: exactly how to organize the check is for the specific organization’s internal control rules to determine. In practice, a working procedure has taken shape.
Full name, date of birth, citizenship, and the position currently or previously held.
From the customer’s own statement to government lists and open publications.
Using additional identifiers, not name alone.
Foreign PEP, official of an international organization, or a Russian position from the circle established by Article 7.3.
Assess the risk level under the organization’s internal control rules.
Apply the requirements for that specific category.
Record the decision made and its grounds.
Place the customer under regular information updates and ongoing monitoring.
For foreign politically exposed persons, this procedure is shorter: the risk assessment doesn’t affect whether the measures apply, and the written decision to accept the customer for service must be made before the customer is actually accepted.
The law is more restrained about this than people usually summarize it. For foreign politically exposed persons, Article 7.3 requires updating information on a regular basis — it doesn’t set a specific frequency. The time frames are set by a different provision and apply to all customers alike: not less often than once every three years for those classified as low risk, not less often than once a year for the rest, and within seven business days if there are doubts about the accuracy of the data. The formula “continuous monitoring” doesn’t exist in 115-FZ at all: it comes from FATF’s Recommendation 12, and in practice it’s implemented through risk-level assessment during servicing and the organization’s internal control rules.
For a detailed look at how PEP screening works after a customer has been identified, and how the risk level is assessed, see “How Sanctions Screening, PEP Checks, and Risk Profiling Work”.
Why a Name Match Alone Isn’t Enough
A name match alone isn’t enough: people with the same surname, common names, different transliteration and spelling variants, and aliases all get in the way. Additional identifiers need to be checked — date of birth, citizenship, country, position, and the period it was held. The mechanics of name normalization, transliteration, and working with secondary identifiers are covered in detail in the article “False Positives in AML Screening”.
Where to Look for Information and Why One Source Isn’t Enough
The 2013 FATF Guidance lists the sources: information obtained during customer due diligence; the organization’s own staff; internet and media searches; commercial databases; PEP lists compiled by states; a financial group’s internal databases; asset-disclosure systems; the customer’s own statement; and information exchange between competent authorities.
There are two limitations here that are rarely written about. A commercial database on its own isn’t enough: FATF states directly that use of these databases is not required by the FATF Recommendations and is not sufficient for compliance with Recommendation 12. And a person’s absence from a government list proves nothing: being on a list can confirm status, but not being on it doesn’t mean the person never held such a position — named lists are difficult and expensive to maintain, they quickly become outdated, and they don’t cover family members. There is no single official worldwide list of politically exposed persons.
What Happens to the Status After Leaving the Position
Neither 115-FZ nor the FATF standards set an automatic time limit after which enhanced measures stop being applied to a person. Article 7.3 itself says nothing at all about former officials. The answer comes from the FATF Guidance — a non-binding document addressed to regulators and financial institutions: the termination of a person’s powers doesn’t by itself mean an automatic end to heightened attention, and further measures are determined by a risk assessment, without being tied to a predetermined deadline. What’s taken into account is how much informal influence the person may still exert, how senior their position was, and whether their former activity is connected to their current one.
For foreign politically exposed persons and officials of international organizations, this applies directly within the Russian framework too: Article 7.3(4) refers the definition of these two categories to the FATF Recommendations, and the FATF definition covers those “who are or have been entrusted” with prominent public functions. There’s no such reference in the law for the Russian category: it’s described through persons holding the relevant positions, and the law doesn’t separately name former officials — here the organization acts on its own risk assessment and internal control rules.
It’s worth distinguishing between the historical record that a person once held such a position — which doesn’t disappear — and the current risk-mitigation measures, which are revisited as the person’s influence and connection to their former position weaken over time.
PEP Status, Sanctions, and Adverse Media: Three Different Checks
PEP status, sanctions status, and mentions in adverse media are three independent checks of a different nature, and they shouldn’t be confused.
| Check | What It Establishes | What a Match Means | What to Do Next |
|---|---|---|---|
| PEP (PDL) | Whether the person holds (or held) a prominent public position; a separate task within the same check is establishing kinship or spousal status with a foreign PEP, which the law requires taking into account in the specified cases | Grounds to apply the measures established for the relevant category | Confirm status using additional identifiers; refusal based on status alone is not justified |
| Sanctions lists | Whether the person is included on a list established by the competent authority of a specific jurisdiction | Legal consequences depend on the regime and jurisdiction | Match identifiers; apply the requirements of the specific regime — OFAC, the EU, and the UK each have different ones |
| Adverse media | Whether open sources contain reports that affect the risk assessment | A signal for the risk assessment, not proof of a violation | Verify reliability and the original source, factor it into the risk assessment |
PEP status doesn’t automatically mean the person is on a sanctions list, and being on a sanctions list doesn’t automatically mean the person is a politically exposed person: these are different institutions — PEP status characterizes a position, while sanctions status is established by the competent authority of a specific jurisdiction. None of these three matches, on its own, means an automatic refusal of service. For more on how the sanctions regimes themselves are structured, see “AML for International Onboarding: How to Screen Customers Against the OFAC, EU, and UK Lists”.
How This Is Automated
Collecting identifiers, matching against lists and commercial databases, and tracking changes over time all lend themselves well to automation. The substantive part is harder to automate: working through a match found, determining the category, and assessing the risk level under internal control rules — automated screening doesn’t replace this part, and the decision remains with the compliance specialist.
PEP Screening at NeuroVision
NeuroVision screens customers against PEP lists, sanctions lists, and adverse media, assesses the significance of matches found rather than just the fact of a match, supports continuous monitoring with change notifications, and works via a REST API. Among the available checks, screening against the list of politically exposed persons (PEP / PDL) is specifically highlighted, along with screening of related legal entities. For more, see AML screening of customers against sanctions and PEP lists.
Sanctions lists, PEP lists, and adverse media — in one check, with an assessment of match significance and continuous monitoring of changes
A politically exposed person is an umbrella term for several categories with different screening regimes: the law itself lists them out in detail and uses the collective phrase only once, in Article 7.1, defining it by reference to Article 7.3. For foreign PEPs, the law sets out the full set of requirements unconditionally, while for the other two categories, the same measures kick in only once the customer has been assigned a high risk level.
Status is not an accusation but a basis for additional measures: the requirements are preventive in nature. A correct check rests on three steps — confirming the person’s identity, determining their category, and applying measures based on risk level — not on a name match alone.
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