US PEP (Politically Exposed Person)
Overview
A U.S. Domestic Politically Exposed Person (PEP) is an individual who currently holds or has held within the last 5 years, a senior public office at the federal, state, or local level. While the United States does not define "PEP" in statute, FinCEN and FATF guidance direct financial institutions to apply enhanced due diligence to individuals in positions of significant public trust and authority.
Pergamon classifies the following roles as domestic PEPs under its U.S. framework: elected and appointed officials at the executive, legislative, and judicial levels, senior military officers, leaders of government-owned entities, and other individuals with substantial public functions. Heads of multilateral or quasi-governmental organizations based in the U.S. are treated as Heads of International Organizations (HIOs) with a 5-year lookback.
Source: FinCEN Advisory FIN-2011-A013, FATF Guidance on Politically Exposed Persons (2023 Update)
About this data
Scope - Domestic United States PEP
This dataset covers individuals who hold or have held within the last 5 years any of the following positions in the United States:
- President, Vice President, Cabinet Secretaries, or equivalent Executive Branch officials
- Members of Congress and State Legislatures
- Governors, Lieutenant Governors, and Mayors of major cities
- Senior federal or state judicial officials (e.g., Justices of the Supreme Court, federal appellate judges)
- Ambassadors or senior diplomatic representatives
- General and flag officers in the Armed Forces (O-7 and above)
- Heads of federal departments, agencies, or independent commissions (e.g., SEC, FTC, FDIC, NASA, FEMA, etc.)
- Chief executives or presidents of government-owned or government-controlled corporations (e.g., Amtrak, TVA, USPS)
- Senior officials of Native American tribal governments recognized by the Bureau of Indian Affairs
- Leaders of major political parties represented at the federal or state level
Relatives & Close Associates (RCA)
Included. Pergamon's RCA framework captures individuals with demonstrable proximity or influence to a Direct PEP, including spouses, children, parents, siblings, and known business or advisory associates. Ancillary influence roles (e.g., chief of staff to a governor, campaign treasurer, senior counsel) are incorporated where material control or influence is evident.
Structure & Linkages
Each record is jurisdiction-tagged (federal, state, or local), role-typed (e.g., Governor, Senator, Agency Head), time-bounded (start/end or "as of"), and linked to RCAs, aliases, and documented name variants to improve match precision in screening workflows.
Frequency of Updates
The U.S. PEP dataset is refreshed weekly to capture changes in officeholders, appointments, and election results, maintaining alignment with FATF and FinCEN expectations for "reasonably current" beneficial ownership and risk data.
Sample Data
Coming soon
Test Our Data
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