RUPEP.org

WHO ARE THE PUBLIC OFFICIALS (PEP)?

Public official (PEP) of Russia:

  • a person who holds the position defined under the federal law "On Combating Money Laundering and Financing of Terrorism";

  • or a person who does not fall within the definition of Russian law but was categorized by us as a national PEP based on recommendations of the Financial Action Task Force on Money Laundering (FATF).


The FATF has identified 4 risk groups among PEP in its recommendations:
1. High-risk: 
- heads of  State or of government;
- senior government (national and regional);
- senior politicians (national and regional);
- heads of military, judicial, law enforcement agencies, board members of central banks; 
- important political party officials.
2. Medium-to-high risk:
- senior military, judicial and law enforcement officials;
- senior officials of other government bodies and senior civil servants;
- senior leaders of religious groups;
- ambassadors, consuls, high commissioners.
3. Medium-risk:
- senior management and members of the board of directors of state enterprises and organizations
4. Low-risk:
- mayors and deputies of local, city and district assemblies;
- senior officials and functionaries of international or supranational organizations.

The public officials associated with the Presidential Administration, the Council of the Federation, State Duma, the Russian Government and the heads of the Federation's constituent entities were investigated by April 2020. So far, PEPs have not been divided into risk groups.

In determining the range of public officials, the Administrator of the Register is guided by the norms of Russian and international law, recommendations of international organizations, in particular:

  1. Federal Law No. 115-FZ of August 7, 2001 on “Countering Money Laundering and the Financing of Terrorism”

  2. FATF Recommendations (Financial Action Task Force on Money Laundering)

  3. Fourth Anti-Money Laundering Directive

  4. 5th Anti-Money Laundering Directive

  5. Decree of the President of the Russian Federation No. 32 of 11 January 1995, “On State Positions of the Russian Federation”

The broad authority and power vested in officials to carry out the Sate functions, is a source of corruption and money laundering risks. Therefore, they are subject to special rules for the control of financial transactions which allow timely identification of cases of money laundering, including bribery, theft, misappropriation or misuse of property and abuse of authority.