PEPs, levelled: extending source-transparent screening to politically exposed persons

Update (2026-07-11). The Wikidata-sourced global PEP dataset described below has been retired under our PEP source policy: every PEP record must trace to a credible government or international-organization publisher, and Wikidata is crowd-sourced. The global layer is now sourced from the CIA World Leaders directory — heads of state, heads of government, and full cabinets for ~199 jurisdictions, current and former officials, with each profile citing its CIA per-country page as the publication of record. The counts and source list below reflect the July 9 launch state and are kept for the historical record; see the data catalog for what is live today.

Sanctions screening answers "is this person or entity on a designated list." Politically-exposed-person (PEP) screening answers a different question: "does this person hold, or has this person held, a position of public trust significant enough that we should look harder before we do business with them." Both are standing requirements for the compliance teams we build for — and until now, we've talked mostly about the first one. This post is about formally extending our coverage, and our transparency posture, to the second.

What's changing

ProofAML's product scope now formally covers PEPs alongside sanctions and watchlist data — not as a bolted-on dataset, but with the same lineage discipline we apply everywhere else: every PEP record traces to a named source and an as-of date, and every classification decision follows a published, consistent methodology rather than a case-by-case judgment call.

Concretely, that methodology has two parts.

A nine-branch government taxonomy. We classify every public-sector position into one of nine branches — executive, legislature, judiciary, military/security, central bank, state-owned enterprises, international-organization officials, subnational/regional government, and political party leadership — so PEP exposure can be reasoned about by the kind of role involved, not collapsed into a single flag.

A four-level seniority model. Within each branch, positions rank as Level 1 (heads of state and government, cabinet ministers, apex judiciary, top military and intelligence leadership, central bank governors — the apex of state power), Level 2 (national legislators, ambassadors, senior civil servants, state-owned-enterprise boards — the bulk of the named-individual PEP population), Level 3 (subnational officials, party leadership — breadth, lower per-record risk), or RCA (family members and close associates of a Level 1 or Level 2 PEP, per FATF's definitions).

Every record also carries a current or former status, derived from the dates a person actually held the position, and a published retention window for how long a former PEP keeps the flag: 50 years for Level 1, 20 years for Level 2, 5 years for Level 3, and — for RCA — whatever window the underlying PEP's own level carries. Those numbers sit well above the EU AMLD's 12-month enhanced-due-diligence floor and reflect a considered position, not an arbitrary one: the FATF standard itself sets no fixed period, requiring only that firms apply risk-based judgment "for as long as appropriate."

Why this is a transparency story, not just a coverage story

We built ProofAML on the position that a screening vendor's data should be as auditable as the decisions built on top of it — every source named, every match traceable to an authority and a list version. That premise turns out to apply to PEP data with, if anything, more force than it applies to sanctions data.

A sanctions list has one issuing authority updating on a predictable schedule. A country's PEP universe doesn't work that way — it's scattered across a parliament's members directory, a cabinet page, a central bank's leadership listing, a state-owned enterprise's annual report, each in its own format, on its own schedule. There is no single-authority equivalent to an OFAC SDN list for PEPs, at the open-data layer or the commercial one. The large incumbent vendors in this space lead with scale claims — profile counts in the millions — more often than they lead with source lineage. We're taking the same position on PEP data that we've taken on sanctions data from day one: name the source, name the as-of date, publish the methodology, and let the buyer check our work instead of taking our word for it.

Coverage

Coverage is live today, and it is global at the apex: 12,236 PEP profiles across 226 jurisdiction values — every country's senior political leadership, plus international organizations. Four datasets feed it:

• Global senior public officials via Wikidata (CC0) — 10,949 profiles (source retired 2026-07-11 — see the update note above; the global layer is now the CIA World Leaders directory) — heads of state and government, cabinet/executive, apex and constitutional judiciary, top military, and central-bank governors, across all ~199 sovereigns plus territories and historical entities.
• European Parliament — all 719 sitting Members (browse the source).
• United States Congress — 537 current members (browse the source).
• UN System senior officials (the CEB roster) — 31 profiles (browse the source) — the first entries in the international-organization branch; 250 profiles across the whole set are international-organization PEPs.

Each profile is classified by branch and seniority — Level 1 (10,463 profiles) at the apex of state power, Level 2 (1,773) one step below — with dates in office, current/former status, source authority, and the retention methodology above rendered right on the page. None of these profiles carries a sanctions section, because a PEP isn't a sanctioned party — the page shows the public-office facts that make the person politically exposed, and nothing more. This sits alongside the sanctions and watchlist coverage that anchors the product.

What's live, stated honestly. The global layer covers each country's senior executive, apex-judicial, top-military, and central-bank leadership, plus international organizations. It is not yet every legislator worldwide, every full cabinet, subnational government, or party leadership — those are the depth we're still building. Full national legislatures are live for exactly two bodies so far: the European Parliament and the US Congress. We would rather name precisely what ships and label the rest as roadmap than claim a breadth we haven't built.

That roadmap fills in depth in three tiers, the same sourcing-priority structure we use for sanctions:

• Tier-1 — full national coverage across every applicable branch (legislatures, full cabinets, subnational, party leadership included) for five sovereign jurisdictions (United States, United Kingdom, Germany, France, Singapore), plus two overlays: an EU-institutional layer (Commission, Parliament, Court of Justice, European Central Bank, Committee of the Regions) and a broader UN/international-organization layer (senior officials of the UN, IMF, World Bank, WTO, NATO, INTERPOL, and equivalent bodies) that extends the UN-system roster already live.
• Tier-2 — 42 further jurisdictions, covering each country's primary branches in depth.
• Tier-3 — the remaining 152 jurisdictions, deepened beyond the apex baseline already live through the same broad, systematic global sourcing (as of 2026-07-11, the CIA World Leaders directory — see the update note above).

That's 199 jurisdictions of hand-sourced depth planned on top of a global apex layer that is already live across 226 jurisdiction values, spanning the full nine-branch taxonomy. See the data catalog for exactly what's live today and what's coming next, and our PEP reference guide for the full plain-language breakdown of the methodology above.

What doesn't change

PEP status is a due-diligence trigger, not an accusation, and our public pages treat it that way: position, branch, level, dates in office, and our retention methodology — no risk score, no editorializing. That's the same framing discipline we apply to sanctions designations, extended to a dataset where it matters just as much.