Data methodology
PEP data methodology.
What PEP means at Verifex, what sources we use, what limitations exist, and why customers must validate source suitability for their regulatory program.
Definition
What PEP means here
At Verifex, "PEP" (Politically Exposed Person) refers to individuals who hold or have held prominent public functions, as well as their family members and known close associates where publicly documented. This aligns with the FATF definition and the EBA/AMLAR framework, but coverage quality depends entirely on the underlying data sources.
Covered roles (where source data supports)
- Heads of state, heads of government, ministers
- Parliamentarians and senior legislators
- Judges of supreme and constitutional courts
- Central bank board members and senior officials
- Ambassadors and senior military officials
- Members of management bodies of state-owned enterprises
Sources
Where the data comes from
Verifex sources PEP data from configured feeds, including Wikidata (CC0 license) where applicable. Wikidata is a community-maintained knowledge base maintained by the Wikimedia Foundation. It is free, structured, and updated continuously by volunteers.
We do not currently license a curated commercial PEP dataset. This is a deliberate transparency choice — and a known limitation. Customers who require regulator-grade PEP coverage should evaluate whether Wikidata-derived feeds meet their NCA's expectations, or consider supplementing with a commercial PEP provider.
Limitations
Known limitations
Wikidata coverage of family members and known close associates varies significantly by jurisdiction. Some countries have extensive relationship data; others have almost none.
Historical records may be incomplete. A PEP who left office five years ago may still be present, or may have been removed, depending on volunteer curation activity.
Record quality depends on volunteer curation. Wikidata has no central editorial control over PEP entries. False positives, duplicates, and outdated records occur.
We apply age and death filtering (pre-1900 born, pre-2000 deceased are generally excluded) to reduce false positives, but edge cases remain.
Verifex does not claim regulator-grade PEP coverage. Customers should validate PEP source suitability for their regulatory program and jurisdiction.
Customer responsibility
What you must validate
Under EBA GL/2024/15 §10–11 and AMLR Article 2(34)/2(35), PSPs and CASPs are expected to define and justify their PEP dataset. Using Verifex does not discharge this obligation. You remain responsible for:
- Confirming that the PEP coverage meets your NCA's expectations
- Documenting your PEP definition and source rationale
- Evaluating whether family/close-associate coverage is adequate for your risk profile
- Supplementing with additional sources if your program requires broader coverage