PEPs in Ireland: who counts, and what you must do differently

Sooner or later, every Irish firm meets a client who is — or is married to, or is in business with — a politically exposed person. For a small practice the moment usually arrives without warning: a routine conveyance, an ordinary tax engagement, and then a screening hit or a half-remembered newspaper article. What you do next is exactly what a supervisor will later examine, because PEP handling is one of the most testable parts of any AML programme. And with the EU's AML Regulation (the AMLR, Regulation (EU) 2024/1624) applying from 10 July 2027, the framework around PEPs is being harmonised EU-wide, making sloppy local habits harder to defend.

Here is who counts, and what has to be different about how you treat them.

Who counts as a PEP?

A politically exposed person is someone who is, or has recently been, entrusted with a prominent public function. The category is about the function, not the person's character — being a PEP is not an accusation, it is a risk classification. The familiar categories include, illustratively:

• Heads of state and government, ministers and deputy ministers
• Members of parliament — in Ireland, members of the Oireachtas
• Members of the governing bodies of political parties
• Senior judges, including members of supreme and constitutional courts
• Ambassadors and high-ranking officers in the armed forces
• Members of the boards of central banks and of court of auditors bodies
• Senior executives of state-owned enterprises

Two points trip firms up. First, domestic PEPs count — the EU framework does not let you treat an Irish officeholder as automatically lower-risk than a foreign one, though the risk assessment of each individual can differ. Second, the status does not vanish the day someone leaves office: enhanced attention continues for a period afterwards on a risk-sensitive basis, tapering as the person's influence genuinely recedes.

Family members and close associates: the part firms miss

The regime deliberately reaches past the officeholder, because value is rarely held in the politician's own name. Family members — typically spouses and partners, children and their spouses or partners, and parents — and known close associates, such as people who share beneficial ownership of an entity with a PEP or have other close business relationships with one, must be treated with the same enhanced care. In screening terms this is usually labelled RCA — relatives and close associates.

This is why a PEP question at onboarding cannot just ask "are you a politically exposed person?". A hypothetical example, clearly hypothetical: a firm onboards a private company whose 30% shareholder is the adult child of a serving foreign minister. The client answers the PEP question honestly — no, they hold no public function — and the firm that never looked at family connections files a clean onboarding that is wrong.

What must you do differently for a PEP?

A PEP relationship is a mandatory enhanced due diligence case. The core measures are consistent across the current Irish framework and the AMLR's harmonised approach:

1. Senior approval. Establishing or continuing the relationship requires sign-off from senior management — in AMLR terms, this sits naturally with your compliance structure of a board-level compliance manager and a compliance officer of sufficiently high standing.
2. Source of wealth and source of funds. You must take adequate measures to establish where the client's overall wealth comes from and where the funds in this relationship come from. For PEPs this is the heart of the exercise: public salaries are knowable, and wealth wildly out of line with a known public career is precisely the signal the regime exists to catch.
3. Enhanced ongoing monitoring. Closer scrutiny of the relationship for as long as it lasts, with shorter review cycles than your standard tier.

None of this means refusing PEPs. A blanket no-PEPs policy is neither required nor particularly sensible; the requirement is deliberate, documented, senior-approved handling.

How do you actually find PEPs in an Irish client base?

Self-declaration plus screening, together — neither is sufficient alone. Ask the question at onboarding, in a form that covers family and close associates, and screen names against PEP data at onboarding and periodically after. Screening throws false positives, especially with common names, so record how each hit was resolved: matched and treated as a PEP, or discounted and why. An unresolved screening hit sitting in an inbox is the worst of all outcomes — it proves you had the information and did nothing. Where a PEP relationship, or any other, gives rise to actual suspicion, the Irish reporting mechanics apply as normal: dual-report to FIU Ireland via the goAML portal and to the Revenue Commissioners via ROS.

What to do now

1. Check your onboarding forms: do they ask about public functions, family members and close associates, or just "are you a PEP?"
2. Confirm every client is screened against PEP data at onboarding, and that periodic re-screening actually runs.
3. Write the PEP procedure down: who gives senior approval, what source-of-wealth evidence is expected, what the enhanced review cycle is.
4. Sweep existing files for unresolved screening hits and close them out with a recorded decision.
5. Train front-line staff to recognise indirect exposure — the shareholder's surname, the spouse's role — not just the direct one.

Where CompliDesk fits

CompliDesk Ireland screens clients and beneficial owners against PEP and sanctions data, routes hits to a recorded resolution, and enforces your senior-approval step so no PEP file moves without it. See it on your own client scenarios — book a demo.