PEEPing at PEPs

George Gilligan (Department of Business Law and Taxation, Faculty of Business and Economics, Monash University, Melbourne, Australia)

Journal of Financial Crime

ISSN: 1359-0790

Publication date: 8 May 2009



The purpose of this paper is to discuss the subject of politically exposed persons (PEPs) and some of the major issues associated with them. PEPs as a specific category are receiving increased attention from governments, law enforcement agencies and international organisations such as the Financial Action Task Force. An increased academic and theoretical focus upon PEPs is required because there is considerable uncertainty about the specific definition of PEPs, how precisely they may be categorised, what the impacts of their activities are and how they might be countered.


This paper first discusses some of the ambiguities surrounding the definition of PEPs. The paper then emphasises the unsurprising reality that definitional confusion regarding PEPs contributes to uncertainty about their incidence and effects. The paper then highlights some of the key policy challenges in responding to PEPs and provides examples of good and bad practice in seeking to counter the activities of PEPs.


The paper concludes that it is important for governments and business organisations to be proactive about emerging risks relating to PEPs. However, experience suggests that it seems extremely difficult to segregate political contexts from how the harms and other problems associated with PEPs might be countered and that political expediency may be a defining overall factor in how responses to PEPs evolve.


The paper's originality and value lies in its efforts to link the definitional and political landscape surrounding the issue of PEPs, and to articulate that progress in the former is unlikely without open appraisal of the impacts of the latter.



Gilligan, G. (2009), "PEEPing at PEPs", Journal of Financial Crime, Vol. 16 No. 2, pp. 137-143.

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