Having a relative in the civil service doesn’t by itself make you a family member of a politically exposed person (PEP). What the UK’s Money Laundering Regulations 2017 require a platform to find out is whether a customer or their beneficial owner is a PEP, or a family member or known close associate of one. Two things settle it, and both have to be checked against the text: whether the post is senior enough to be a prominent public function, and whether your relationship to the person is on the list.
If both match, or you hold that kind of post yourself, tick “Yes” and have paperwork ready that shows where your money comes from. If the post is clearly below that level, or the relationship isn’t on any of the lists, answer “No”. If you’re somewhere in between and can’t tell, tick “Yes” as well, and when the platform follows up, explain who the relative is, what post they hold and the year they left it. Don’t talk the post down to save yourself a round of checks, and don’t skip the box.
Which posts UK and EU anti-money laundering rules treat as prominent public functions
When regulation 35(12) of the UK rules defines a PEP, it sets a seniority threshold: middle-ranking and more junior officials are excluded. The posts that count as prominent public functions are in paragraph (14). That list isn’t closed, so a post left off it hasn’t been expressly ruled out.
Regulation (EU) 2024/1624, which applies from 10 July 2027, has its own list in Article 2(1)(34), and Article 2(2) sets the same seniority threshold. The two lists broadly line up, with the EU one going into more detail on political parties, state-owned enterprises and local leaders.
| Post | UK regulation 35(14) | EU Article 2(1)(34) |
|---|---|---|
| Head of state, head of government, minister, deputy or assistant minister | Listed | Listed |
| Member of parliament or a similar legislative body | Listed | Listed |
| Member of a political party’s governing body | Listed | Only parties with seats in a national executive or legislative body, or in a regional or local one representing a constituency of at least 50,000 inhabitants |
| Member of a supreme court, a constitutional court or a judicial body whose decisions can’t be appealed except in exceptional circumstances | Listed | Listed |
| Member of a court of auditors or a central bank board | Listed | Listed |
| Ambassador, chargé d’affaires, high-ranking officer in the armed forces | Listed | Listed |
| Member of the administrative, management or supervisory body of a state-owned enterprise | Listed | State-controlled enterprises; medium-sized or large enterprises controlled by regional or local authorities count too |
| Senior figures at international organisations | Directors, deputy directors, board members or equivalent | Highest-ranking official and deputies, board members or equivalent, and representatives to a member state or the EU |
| Heads of regional and local authorities | Not named | Listed where the area has at least 50,000 inhabitants |
For countries outside the EU, the EU regulation adds that functions equivalent to those posts in member states count as well. When you compare, look at the post itself: is it at the level of minister, legislator, senior judge, ambassador or state-enterprise board member, or is it an ordinary staff job in a department? Neither regulation maps these to Chinese civil-service grades, so which side of the line a division director or section chief falls on is for the platform to decide.
How financial institutions in China identify foreign PEPs and their related persons under Article 33
China’s Measures on Customer Due Diligence and the Retention of Customer Identity Information and Transaction Records by Financial Institutions (official text in Chinese), issued jointly by the People’s Bank of China, the National Financial Regulatory Administration and the China Securities Regulatory Commission, took effect on 1 January 2026 and replaced earlier measures from 2007 and 2022. They apply to financial institutions set up within China, including banks, securities, futures and fund management companies, insurers and non-bank payment institutions.
Article 33 requires financial institutions to take reasonable steps to establish whether a customer or their beneficial owner is a foreign PEP, a senior manager of an international organisation, or a specified related person of either. Where it’s a foreign PEP or a related person of one, the institution has to find out the source and intended use of the funds or assets, get senior management approval to set up or keep the business relationship, and step up ongoing monitoring of the customer and the relationship. For senior managers of international organisations and their related persons, those measures apply only where the risk is higher.
The article counts both current and former holders of important public functions abroad as foreign PEPs, with examples running from heads of state and government to senior executives of state-owned enterprises and leading party figures.
Specified related persons have their own scope in the same article: close relatives such as parents, spouses and children, plus other individuals with a shared interest arising from work, daily life or similar ties. The UK rules split these people into family members and known close associates; the Chinese measures put them together under one term.
Article 33 names foreign PEPs only. The UK rules draw a different line: someone entrusted with a prominent public function by the UK is a domestic PEP, and everyone else is a non-domestic PEP. For a platform bound by those rules, a minister-level official in China is a non-domestic PEP. Paragraph (3A) tells platforms to start from a lower level of risk for domestic PEPs, their family members and known close associates than for non-domestic PEPs.
Do siblings of an official count as family members of a PEP?
Of the three sets of rules, only the EU regulation names siblings, and only where the office holder is a head of state, head of government, minister, deputy or assistant minister, or holds an equivalent post at EU level or in a third country. Member states can also widen the scope for siblings to suit national circumstances. Neither the UK rules nor the Chinese measures list them.
| Your relationship to the office holder | UK regulation 35(12) | EU Article 2(1)(35) and (36) | China Article 33 |
|---|---|---|---|
| Spouse | Listed, including civil partner | Listed, including registered partner, civil union or similar arrangement | Listed |
| Child | Listed | Listed | Listed |
| Child’s spouse | Listed | Listed | Not named |
| Parent | Listed | Listed | Listed |
| Sibling | Not named | Listed where the office holder is a head of state, head of government, minister, deputy or assistant minister | Not named |
| Joint beneficial ownership of a company or other legal arrangement with the office holder, or other close business relations | Known close associate | Known close associate | Not listed separately (the measures also cover “other individuals with a shared interest arising from work, daily life or similar ties”) |
| Sole beneficial ownership of a company or legal arrangement set up for the office holder’s benefit | Known close associate | Known close associate | Not listed separately (the measures also cover “other individuals with a shared interest arising from work, daily life or similar ties”) |
Both the UK’s family member wording and China’s close relatives wording leave the door open. A relationship marked “Not named” can’t be taken as definitely outside the rules.
Uncles, aunts and cousins aren’t named in any of the three. If one of them co-owns a company or runs a business with the office holder, compare them against the last two rows of the table instead. Regulation 35(15) says that in deciding who is a known close associate, a platform need only look at information it holds and credible information that is publicly available.
Don’t be surprised if one platform asks about a sibling and another doesn’t. The three lists don’t reach equally far to begin with.
How long after a relative leaves office do they stop being treated as a PEP?
The UK and EU rules both set a floor of 12 months after the office holder leaves. Where they part ways is on the family.
| Rules | The office holder after leaving | Their family members and known close associates |
|---|---|---|
| UK regulation 35(9) and (11) | For at least 12 months the platform keeps applying the measures in paragraphs (5) and (8), and longer if it thinks that’s needed | Once the office holder has left, the platform no longer has to apply those measures to them, whether or not the 12 months are up |
| EU Articles 45 and 46 | The platform has to consider the continuing risk from the former post and take measures until that risk is gone, and in any case for at least 12 months | Article 46 applies the measures in Articles 42, 44 and 45 to family members and known close associates as well |
| China Article 33 | Former holders of important public functions count as foreign PEPs; the article gives no time limit and sets no separate rule for related persons once someone leaves office | |
On the questionnaire, still include a relative who has left office and note the month and year they left. The 12 months in the table is a floor for the office holder. When a particular relative stops counting is for the platform to decide under the rules that bind it, so don’t count the days and change your answer on your own.
Before you tick the PEP box, check your own posts and your relatives’ one by one
Take a sheet of paper and work down this list in order. Write the facts at every step and don’t guess anyone’s grade for them.
- Start with yourself: every public post you hold now or have held, with the full title, followed by the month and year you started and finished.
- Then your relatives: give your spouse, children, children’s spouses and parents a line each, and start a new line for siblings. Note the post each one holds or has held, and write “None” if they’ve had no public post.
- Check seniority against the first table. Tick anything that matches. If a post sits somewhere between an ordinary department staffer and a minister and you can’t say which, put a question mark.
- Check business ties: do you co-own a company with an office holder, or solely own one set up for their benefit? If you do, compare against the two known close associate rows.
- One tick or question mark means you tick “Yes” in this box. Then gather the paperwork that explains where all your assets came from. Source of Wealth vs Source of Funds in Crypto KYC sets out what a source of wealth explanation has to cover, and Why You Were Asked to Prove Your Source of Funds deals with where the money for a particular transaction came from.
- No ticks and no question marks: answer truthfully and keep the sheet. If a relative later changes post or leaves office, or you take on a public post yourself, go through it again and contact the platform to update anything that has changed.
Once a platform decides you fall into this category, it may ask for further explanations and documents. Whatever you add has to tell the same story as the occupation and income details you’ve already given that platform. For the rule behind each of the other boxes on the questionnaire, see Why KYC Asks Your Occupation, Income and Purpose.