Politically Exposed Persons (PEP) Screening

PEP classification follows FATF Recommendation 12 adapted for the unique governance landscape of GCC markets, where ruling families, sovereign wealth funds, and state enterprises are deeply intertwined with listed company boards.

Classification Categories

• Ruling Family: Members of GCC ruling families identified through the is_ruling_family flag and family name matching
• SWF Representative: Directors linked to sovereign wealth funds (ADIA, Mubadala, PIF, QIA, KIA, ADQ, ICD, Mumtalakat, OIA) via role text or direct flags
• Government Appointee: Detected through role patterns (minister, governor, undersecretary, Shura council, Majlis) across both NZX-style appointments and cross-entity shared positions
• Regulator: Current or former officials at securities regulators (CMA, SCA, DFSA, FSRA, QFMA, CBB, central banks)
• State Enterprise: Directors at companies with >50% government ownership, cross-referenced with conglomerate group data
• Merchant Family: Members of established merchant families identified via the merchant_families table and name matching
• Military / Security: Defence, national guard, intelligence, and internal security roles

Risk Level Assignment

Risk levels are assigned based on category and role currency:

• High: Ruling family members (always), current government appointees, active SWF representatives
• Medium: Former government/SWF roles, current regulators, military/security connections
• Low: Merchant family connections, state enterprise directors (non-government role)

Regulatory Context

GCC regulators enforce PEP-related due diligence under several frameworks:

• FATF Recommendations 12 & 22: Enhanced due diligence for PEPs in financial relationships
• UAE AML/CFT Federal Law (2018, amended 2024): Requires identification and monitoring of PEPs including domestic officials and their family members
• Saudi AMLA (Anti-Money Laundering Law): Enhanced CDD obligations for PEP relationships under CMA Implementing Regulations
• Bahrain CBB Rulebook (FC Module): PEP identification requirements for licensees
• Qatar QFMA Regulations: AML/CFT compliance including PEP screening for market participants

Data Sources

PEP classification draws from multiple data sources: director appointment records, ruling family and SWF flags on directors, cross-platform positions from shared.positions, merchant family databases, conglomerate group memberships, and top-20 shareholder government ownership analysis.