PEP STATUS SECTION
Style/formatting: Follow ~/.claude/skills/word-doc-generator/SKILL.md
Purpose
Politically Exposed Person assessment. Determines PEP classification, level, and associated risks.
TEMPLATE
## Political Exposure
[IF NOT PEP:]
### PEP Screening
**[SUBJECT]** was screened against PEP databases and public records. No political exposure was identified. **[SUBJECT]** does not appear to hold or have held a prominent public function, nor to be a close family member or associate of a PEP.
[IF PEP:]
### PEP Classification
**[SUBJECT]** is classified as a Politically Exposed Person (PEP).
| Field | Details |
|-------|---------|
| **PEP Type** | [Domestic / Foreign / International Organization] |
| **PEP Level** | [PEP1 (direct) / PEP2 (family/associate)] |
| **Category** | [Head of State / Minister / Parliamentarian / etc.] |
| **Position** | [SPECIFIC ROLE] |
| **Jurisdiction** | [COUNTRY] |
| **Tenure** | [START DATE] - [END DATE / Present] |
| **Status** | [Current / Former] |
### Political Roles
| Period | Position | Institution | Jurisdiction |
|--------|----------|-------------|--------------|
| [DATES] | [ROLE] | [INSTITUTION] | [COUNTRY] |
| [DATES] | [ROLE] | [INSTITUTION] | [COUNTRY] |
### Political Affiliations
**[SUBJECT]** is affiliated with [PARTY NAME], [DESCRIPTION OF PARTY].[^X]
[IF FAMILY/ASSOCIATE PEP:]
### PEP Association
**[SUBJECT]** is classified as a PEP associate due to [his/her] relationship with **[PEP NAME]**, [PEP ROLE].[^X]
| Related PEP | Relationship | PEP Role |
|-------------|--------------|----------|
| **[NAME]** | [Spouse / Parent / Child / Business associate] | [ROLE] |
### Risk Considerations
[SELECT APPLICABLE:]
**Corruption Risk:**
> [COUNTRY] is ranked [RANK] out of [TOTAL] countries on Transparency International's Corruption Perceptions Index [YEAR], indicating [high / moderate / low] corruption risk.[^X]
**Sanctions Nexus:**
> [COUNTRY/REGIME] is subject to international sanctions. **[SUBJECT]**'s political role may expose [him/her] to sanctions risk.
**State-Owned Enterprises:**
> **[SUBJECT]**'s role at [STATE ENTITY] creates potential exposure to state-controlled enterprises.
**Defense/Security:**
> **[SUBJECT]** has held positions in [defense / security / intelligence], which may attract heightened scrutiny.
RULES
MUST Include
- Clear PEP/Non-PEP determination
- For PEPs: Category, level, role, dates
- For PEP associates: Relationship to PEP
- Risk context (TI ranking, sanctions status)
MUST NOT
- Classify as PEP without clear evidence
- Omit tenure dates for political roles
- Fail to distinguish current vs former PEP
- Miss family/associate PEP status
PEP CATEGORIES
Tier 1 - Highest Risk
| Category |
Examples |
| Head of State/Government |
President, Prime Minister, Monarch |
| Senior Government |
Cabinet Ministers, Deputy Ministers |
| Senior Judiciary |
Supreme Court, Constitutional Court |
| Senior Military |
General officers, Intelligence chiefs |
| Central Bank |
Governor, Board members |
| State Enterprise |
CEO/Chairman of major SOEs |
| International Organizations |
UN, IMF, World Bank senior officials |
Tier 2 - High Risk
| Category |
Examples |
| Parliamentarians |
MPs, Senators, Legislators |
| Regional Government |
Governors, Mayors of major cities |
| Senior Diplomats |
Ambassadors, Consul Generals |
| Political Party |
Party leaders, senior officials |
| Regulators |
Heads of regulatory agencies |
Tier 3 - Moderate Risk
| Category |
Examples |
| Mid-level Officials |
Director-level, department heads |
| Local Government |
Local council members |
| Former PEPs |
Depending on time since leaving office |
| PEP Associates |
Family members, close business associates |
STANDARD PHRASES
Current PEP:
[SUBJECT] is a current Politically Exposed Person, serving as [ROLE] of [INSTITUTION] since [DATE].
Former PEP:
[SUBJECT] is a former PEP, having served as [ROLE] from [DATE] to [DATE]. [He/She] left office [X] years ago.
Family member PEP:
[SUBJECT] is the [spouse / child / parent] of [PEP NAME], [PEP ROLE], and is therefore classified as a PEP family member.
Close associate PEP:
[SUBJECT] is classified as a PEP close associate due to [his/her] documented business relationship with [PEP NAME].
Not a PEP:
No political exposure was identified for [SUBJECT]. [He/She] does not appear to be a PEP or PEP associate.
High-risk jurisdiction:
[SUBJECT]'s political role in [COUNTRY], combined with the jurisdiction's [high corruption risk / weak governance], warrants enhanced scrutiny.
PEP TIMEFRAMES
| Jurisdiction |
PEP Period After Leaving Office |
| FATF Guidance |
Minimum 12 months, risk-based beyond |
| UK (FCA) |
Risk-based, no fixed period |
| EU (4AMLD) |
12 months minimum |
| US (FinCEN) |
Risk-based, no fixed period |
| Singapore (MAS) |
12 months minimum |
DISCLAIMER
PEP status is determined based on available public information and screening databases. Classification may differ between institutions based on their risk appetite and regulatory requirements.
FOOTNOTE FORMAT
See word-doc-generator/SKILL.md - URL-only footnotes.
1---2name: universal3description: Universal4---5
6# PEP STATUS SECTION
7
8> **Style/formatting:** Follow `~/.claude/skills/word-doc-generator/SKILL.md`
9
10## Purpose
11
12Politically Exposed Person assessment. Determines PEP classification, level, and associated risks.
13
14---
15
16## TEMPLATE
17
18```markdown
19## Political Exposure
20
21[IF NOT PEP:]
22### PEP Screening
23
24**[SUBJECT]** was screened against PEP databases and public records. No political exposure was identified. **[SUBJECT]** does not appear to hold or have held a prominent public function, nor to be a close family member or associate of a PEP.
25
26[IF PEP:]
27### PEP Classification
28
29**[SUBJECT]** is classified as a Politically Exposed Person (PEP).
30
31| Field | Details |
32|-------|---------|
33| **PEP Type** | [Domestic / Foreign / International Organization] |
34| **PEP Level** | [PEP1 (direct) / PEP2 (family/associate)] |
35| **Category** | [Head of State / Minister / Parliamentarian / etc.] |
36| **Position** | [SPECIFIC ROLE] |
37| **Jurisdiction** | [COUNTRY] |
38| **Tenure** | [START DATE] - [END DATE / Present] |
39| **Status** | [Current / Former] |
40
41### Political Roles
42
43| Period | Position | Institution | Jurisdiction |
44|--------|----------|-------------|--------------|
45| [DATES] | [ROLE] | [INSTITUTION] | [COUNTRY] |
46| [DATES] | [ROLE] | [INSTITUTION] | [COUNTRY] |
47
48### Political Affiliations
49
50**[SUBJECT]** is affiliated with [PARTY NAME], [DESCRIPTION OF PARTY].[^X]
51
52[IF FAMILY/ASSOCIATE PEP:]
53### PEP Association
54
55**[SUBJECT]** is classified as a PEP associate due to [his/her] relationship with **[PEP NAME]**, [PEP ROLE].[^X]
56
57| Related PEP | Relationship | PEP Role |
58|-------------|--------------|----------|
59| **[NAME]** | [Spouse / Parent / Child / Business associate] | [ROLE] |
60
61### Risk Considerations
62
63[SELECT APPLICABLE:]
64
65**Corruption Risk:**
66> [COUNTRY] is ranked [RANK] out of [TOTAL] countries on Transparency International's Corruption Perceptions Index [YEAR], indicating [high / moderate / low] corruption risk.[^X]
67
68**Sanctions Nexus:**
69> [COUNTRY/REGIME] is subject to international sanctions. **[SUBJECT]**'s political role may expose [him/her] to sanctions risk.
70
71**State-Owned Enterprises:**
72> **[SUBJECT]**'s role at [STATE ENTITY] creates potential exposure to state-controlled enterprises.
73
74**Defense/Security:**
75> **[SUBJECT]** has held positions in [defense / security / intelligence], which may attract heightened scrutiny.
76```
77
78---
79
80## RULES
81
82### MUST Include
83- Clear PEP/Non-PEP determination
84- For PEPs: Category, level, role, dates
85- For PEP associates: Relationship to PEP
86- Risk context (TI ranking, sanctions status)
87
88### MUST NOT
89- Classify as PEP without clear evidence
90- Omit tenure dates for political roles
91- Fail to distinguish current vs former PEP
92- Miss family/associate PEP status
93
94---
95
96## PEP CATEGORIES
97
98### Tier 1 - Highest Risk
99
100| Category | Examples |
101|----------|----------|
102| **Head of State/Government** | President, Prime Minister, Monarch |
103| **Senior Government** | Cabinet Ministers, Deputy Ministers |
104| **Senior Judiciary** | Supreme Court, Constitutional Court |
105| **Senior Military** | General officers, Intelligence chiefs |
106| **Central Bank** | Governor, Board members |
107| **State Enterprise** | CEO/Chairman of major SOEs |
108| **International Organizations** | UN, IMF, World Bank senior officials |
109
110### Tier 2 - High Risk
111
112| Category | Examples |
113|----------|----------|
114| **Parliamentarians** | MPs, Senators, Legislators |
115| **Regional Government** | Governors, Mayors of major cities |
116| **Senior Diplomats** | Ambassadors, Consul Generals |
117| **Political Party** | Party leaders, senior officials |
118| **Regulators** | Heads of regulatory agencies |
119
120### Tier 3 - Moderate Risk
121
122| Category | Examples |
123|----------|----------|
124| **Mid-level Officials** | Director-level, department heads |
125| **Local Government** | Local council members |
126| **Former PEPs** | Depending on time since leaving office |
127| **PEP Associates** | Family members, close business associates |
128
129---
130
131## STANDARD PHRASES
132
133**Current PEP:**
134> **[SUBJECT]** is a current Politically Exposed Person, serving as [ROLE] of [INSTITUTION] since [DATE].
135
136**Former PEP:**
137> **[SUBJECT]** is a former PEP, having served as [ROLE] from [DATE] to [DATE]. [He/She] left office [X] years ago.
138
139**Family member PEP:**
140> **[SUBJECT]** is the [spouse / child / parent] of **[PEP NAME]**, [PEP ROLE], and is therefore classified as a PEP family member.
141
142**Close associate PEP:**
143> **[SUBJECT]** is classified as a PEP close associate due to [his/her] documented business relationship with **[PEP NAME]**.
144
145**Not a PEP:**
146> No political exposure was identified for **[SUBJECT]**. [He/She] does not appear to be a PEP or PEP associate.
147
148**High-risk jurisdiction:**
149> **[SUBJECT]**'s political role in [COUNTRY], combined with the jurisdiction's [high corruption risk / weak governance], warrants enhanced scrutiny.
150
151---
152
153## PEP TIMEFRAMES
154
155| Jurisdiction | PEP Period After Leaving Office |
156|--------------|--------------------------------|
157| **FATF Guidance** | Minimum 12 months, risk-based beyond |
158| **UK (FCA)** | Risk-based, no fixed period |
159| **EU (4AMLD)** | 12 months minimum |
160| **US (FinCEN)** | Risk-based, no fixed period |
161| **Singapore (MAS)** | 12 months minimum |
162
163---
164
165## DISCLAIMER
166
167> PEP status is determined based on available public information and screening databases. Classification may differ between institutions based on their risk appetite and regulatory requirements.
168
169---
170
171## FOOTNOTE FORMAT
172
173**See `word-doc-generator/SKILL.md`** - URL-only footnotes.