Political Exposed Persons (PEPs), is an individual who is or has been entrusted with a prominent function. Many PEPs hold positions that can be abused for the purpose of laundering illicit funds or other predicate offenses such as corruption or bribery.
Making PEPs dataset available and opened would be a valuable resource for many use cases:
However, there are limited open data sets for political exposed persons in Southeast Asia. A more comprehensive set of open data for PEPs that is reusable across the region will be useful for multiple actors and for cross-border collaborations. Locally sourced data compliant to national laws and regulatory definitions will also ensure some level of protection from legal persecution when reporting on anti-corruption issues.
This guide provides a practical framework in 2 main steps: 1) Defining who is PEPs by mapping PEPs definition in your context following FATF guideline, and 2) Structuring dataset following Popolo guideline, to align with the partnerships data standard. These 2 steps will enable knowledge sharing and empower the cross-border investigation between network partners and anyone who follows this guideline.
The Financial Action Task Force (FATF) published FATF Guidance: Politically Exposed Persons (Recommendations 12 and 22) categorized PEPs into 5 groups.
Individuals who are or have been entrusted with prominent public functions by a foreign country; for example heads of states or of government, senior politicians, senior judicial or military officials, senior executives of state owned corporations, important political party officials.
| Indonesia | Malaysia | Thailand |
|---|---|---|
Individuals entrusted with a prominent public function by a foreign state. This includes foreign heads of state or government, senior politicians, senior government officials, senior military or law-enforcement officials, senior executives of foreign state-owned enterprises, and senior officials of foreign political parties. Bank Indonesia and the Ministry of Finance also recognized foreign PEPs as high-risk persons requiring EDD. Defined by OJK (POJK 8/2023; SEOJK 11/2021) | Individuals who are or who have been entrusted with prominent public functions by a foreign country. For example, Heads of State Government, senior politicians, senior government, judicial or military officials, senior executives of state-owned corporations and important political party officials; (BNM) State-owned corporations not clearly defined. | Foreign Politically Exposed Persons (Foreign PEPs) include:
All of the above shall be regarded as Politically Exposed Persons (PEPs) if their positions are equivalent to those of Domestic PEPs |
Swipe for more informationindividuals who are or have been entrusted domestically with prominent public functions; 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.
persons who are or have been entrusted with a prominent function by an international organization, refers to members of senior management or individuals who have been entrusted with equivalent functions, i.e. directors, deputy directors and members of the board or equivalent functions.
are individuals who are related to a PEP either directly (consanguinity) or through marriage or similar (civil) forms of partnership.
are individuals who are closely connected to a PEP, either socially or professionally.
After we know who should be considered as PEPs, we can start collecting the data. Data standard is a “Set of designed data structures for a specific purpose”. In this study, we want to propose one for PEPs because it will provide the following benefits:
Our proposed standard is based on Popolo: International open government data specifications which were adopted by many public sectors and civic tech e.g. My Society (UK), g0v (Taiwan), and Sinar Project (Malaysia). The standard itself is not tied to any specific data storage and formats, you can use a full feature database or starting with just Google Sheets which is highly recommended if you want to get started with limited technical resources.
The PEPS dataset should contain 6 entities, each entity might be represented as a table or a spreadsheet.
Describe the person who qualified as PEPS as defined in the previous section.
| Field / Column Name | Data Type | Description |
|---|---|---|
| id | Text | Unique identifier |
| name | Text | A person's preferred full name |
| other_name | List of text | An alternate name, such as a pseudonym |
| Text | A preferred email address | |
| gender | Text | A gender |
| birth_date | Date | A date of birth |
| death_date | Date | A date of death |
| image | Text | A URL of a head shot |
| summary | Text | A one-line account of a person's life |
| biography | Text | An extended account of a person's life |
| national_identity | Text | A national identity |
| contact_details | List of text | A means of contacting the person |
| links | List of text | A URL to a document about the person |
Describe any kind of related organization: government body, private organization, etc.
Describe the position of each organization. This table should have the following columns:
Connect the person to the position in a membership relationship.
Describe the relation between two people that would make a person become PEPS as described in the previous section.
Internationalization
To be able to use across datasets with the same standard at the international level, English name, and translation is important. However, we propose to use the local official language by default, then if the English name and translation for each column will be appended _en at the end of column name e.g. name and name_en
Why use the local language by default?
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