Schedule 2 of the AMLO defines a politically exposed person by the function held: a head of state or government, a senior politician, a senior government, judicial or military official, a senior executive of a state-owned corporation, or an important political party official, together with the person's spouse, partner, children and parents and close associates. Since 1 June 2023 the ordinance separates non-Hong Kong PEPs, who hold the function in a place outside Hong Kong, from Hong Kong PEPs, and recognises international organisation PEPs. Officials in Mainland China now count as non-Hong Kong PEPs.
The treatment differs. For a foreign PEP, section 10 requires enhanced due diligence: senior management approval before the relationship starts or continues, reasonable measures to establish the source of wealth and the source of funds, and enhanced ongoing monitoring. For domestic and international organisation PEPs the measures apply on a risk-sensitive basis, and the HKMA's guideline explains how a bank decides. A person who no longer holds the function is treated according to the risk that remains.
Why it matters
PEP status is not an accusation. It flags a position that can be abused for corruption, so the firm must know where the customer's wealth came from before it accepts it. Screening a name against PEP lists is only the first step; the file must show the decision.
How Fill Easy relates to it
GovVerify can add AML and sanctions screening to an identity request for all four schemes, and the result lands in the signed audit record alongside the government-confirmed identity. For the corporate side, CorpVerify names the directors and traced owners, which is who the PEP screen should cover.