PEP Policy

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Purpose

This policy defines how Minerva identifies, ingests, classifies, and retains Politically Exposed Person (PEP) data when using third-party source data, including OpenSanctions, as an upstream input. The goal is to ensure Minerva has a clear, defensible, and operationally useful standard for:

• what qualifies as a PEP
• what related persons are included
• how records are classified
• how long records remain in scope
• how external source data is translated into Minerva’s internal policy

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Policy objective

Minerva ingests PEP-related data from external providers. Because external datasets are designed for broad coverage and not necessarily for one-to-one operational use in Minerva, source data must be normalized into a Minerva-defined policy standard. Minerva therefore treats upstream source definitions as an input, not as the final policy authority.

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Minerva definition of a PEP

Minerva defines a Politically Exposed Person as: This includes persons holding qualifying roles at the national, intergovernmental, regional, sub-national, and relevant local level, as well as certain senior persons connected to state-owned enterprises, public agencies, diplomatic functions, security institutions, and political parties. Minerva separately recognizes Relatives and Close Associates (RCA) of qualifying PEPs, but does not treat them as office-holding PEPs. RCA records are included as a distinct classification.

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Guiding principles

Minerva’s PEP policy is based on the following principles:

• Role-based inclusion
  A person is included because they occupy or occupied a qualifying position, not merely because they are politically adjacent.
• Risk-based scope
  The higher the level of public authority, access to state resources, regulatory influence, or political control, the stronger the presumption of inclusion.
• Separate treatment of RCA
  Family members and close associates of PEPs are relevant to compliance risk, but are classified separately from the office-holder.
• Coverage with controlled precision
  Upstream source data may contain newly created or partially classified roles. Minerva should not depend solely on perfectly tagged categories when determining scope.
• Explainability
  Every included record should, where possible, be traceable to a role, jurisdiction, time period, and source rationale.

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Evidence and source evaluation

Minerva evaluates PEP inclusion based on credible evidence of public office, role occupancy, relationship data, jurisdiction, and timing. Minerva may ingest data from third-party sources, public records, corporate records, official websites, and other research inputs, but Minerva applies its own internal policy standard when determining whether a person should be included. Some PEP determinations are straightforward, particularly where a qualifying office can be tied to an official title, term, and jurisdiction. Other determinations are more subjective, especially in the case of relatives and close associates. Where Minerva is able to identify compelling evidence, supporting references, or credible source material showing that a person is a relative or close associate of a qualifying PEP, Minerva may include that individual as an RCA under its policy. However, a passing mention in a news article, an unsupported reference to a relationship, or a speculative association does not automatically justify PEP inclusion at Minerva. Relationship-based inclusion requires sufficient supporting evidence to make the classification defensible. Minerva’s objective is not simply to assign a label. The goal is to provide enough supporting documentation, source references, and linked evidence so that, in the event of an alert, the client has sufficient context to review and action the result.

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Primary inclusion categories

The following categories are included in Minerva’s PEP universe by default.

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1. National government and state leadership

Included:

• Head of state
• Head of government
• National executive and cabinet members
• National legislature members
• Senior national court judges and prosecutors
• Senior military, police, intelligence, and security leadership
• Central bank leadership
• Ambassadors and senior diplomatic leadership

Rationale: These roles represent the clearest and most widely recognized PEP categories due to political authority, decision-making power, influence over public resources, and corruption exposure.

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2. Intergovernmental organization leadership

Included:

• Senior leadership of intergovernmental organizations
• Legislators or equivalent senior governing officers of intergovernmental bodies where relevant

Rationale: These roles may involve influence over public policy, cross-border funding, diplomatic authority, or international regulatory decision-making.

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3. Regional or sub-national public office

Included:

• Governors, premiers, and equivalent regional heads of government
• Regional executive and cabinet members
• Regional legislature members
• Senior regional judges

Rationale: These roles may control substantial public budgets, procurement, regulation, licensing, and politically sensitive administrative decisions.

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4. Relevant local public office

Included:

• Mayors and equivalent local heads of government
• Members of local executive bodies
• Local legislators or council members where the role has meaningful public authority

Rationale: Local office is in scope where the role has real influence over public funds, procurement, land use, licensing, municipal services, policing, or politically exposed decision-making.

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5. State-owned enterprises and public agencies

Included:

• Senior executives
• Board members
• Other senior decision-makers of state-owned enterprises, sovereign entities, and public agencies reporting to government

Rationale: These individuals may exercise control over public assets, procurement, contracts, state resources, licensing, and politically sensitive commercial decisions.

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6. Political party leadership

Included:

• Senior leaders of political parties
• Other high-ranking party officials where the role indicates material political influence

Rationale: Senior party leadership may carry influence over candidate selection, policy direction, patronage, government formation, or state access.

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Relatives and Close Associates

Minerva includes relatives and close associates of qualifying PEPs when supported by source evidence or policy rules. RCA records are classified separately from PEP office-holders. RCA may include:

• spouses or partners
• children
• parents
• siblings
• other close family members where relevant
• known business associates
• trusted intermediaries or nominees
• other close associates linked by a credible relationship to the PEP

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RCA classification rule

A relative or close associate is not itself treated as an office-holder PEP unless that person independently holds a qualifying PEP office.

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Explicit exclusions

The following are excluded from Minerva’s default PEP scope unless a client-specific policy requires broader treatment:

• ordinary civil servants without meaningful public decision-making authority
• low-level municipal staff
• junior employees of public agencies or state-owned enterprises
• administrative or clerical personnel without public authority
• individuals who are politically adjacent but hold no qualifying office and have no supported RCA relationship
• persons lacking sufficient identity, role, or timing evidence

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Inclusion timing and lookback rules

Minerva uses a role-sensitive lookback approach.

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Default lookback periods

• National positions: 20 years after leaving office
• Intergovernmental positions: 20 years after leaving office
• All other qualifying positions: 5 years after leaving office

These windows govern whether a record remains actively in scope for Minerva’s PEP classification unless stricter customer policy or jurisdiction-specific requirements apply.

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If end dates are unavailable

Where source data does not provide reliable end dates, Minerva may classify the status as unclear and retain the record temporarily where there is sufficient evidence that the person held a qualifying position. Where there is no usable birth date, death date, role timing, or other basis for determining current or historical relevance, the record should be excluded from active policy scope.

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Ingestion and normalization rules

When Minerva ingests upstream or third-party PEP-related data, the following rules apply:

• records identified as PEP candidates should be treated as upstream signals for Minerva review
• relatives and close associates should be classified separately from office-holders
• position and occupancy data should be used to determine role type, jurisdiction, and timing
• Minerva should not rely solely on a single mention, weak association, or incomplete third-party tag when determining final inclusion
• where classification is incomplete, Minerva may retain the record for review if there is credible evidence of a qualifying role or relationship
• Minerva must apply its own exclusion, confidence, identity-resolution, and timing logic before exposing records downstream
• Minerva should seek to preserve sufficient supporting documentation, source references, and links so clients can understand and action a resulting alert

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Operational policy for ambiguous records

Where a record appears politically relevant but classification is incomplete, Minerva should:

• retain the record for review if there is credible evidence of a qualifying position
• classify it as unclear where status cannot be confidently determined
• avoid suppressing the record solely because detailed source taxonomy is not yet complete
• exclude only where there is sufficient evidence that the person is outside Minerva’s policy scope

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Policy statement

Minerva’s PEP definition and inclusion standard is based on a role-based, risk-sensitive approach. Upstream data sources are used as ingestion inputs and research references, but Minerva applies its own internal normalization, exclusion rules, evidence standards, and status model to determine active policy scope. In practice, Minerva includes qualifying public office-holders across national, intergovernmental, regional, and relevant local government, as well as senior persons in state-linked entities and political parties. Minerva also includes relatives and close associates of qualifying PEPs as a distinct RCA class where supported by sufficient evidence. Minerva can also apply jurisdiction-specific overlays, including FINTRAC, FinCEN / U.S., and UK identification views, to help clients map Minerva records to the categories most relevant to their regulatory obligations. This policy is intended to create a defensible, explainable, and operationally consistent foundation for Minerva’s PEP screening and risk workflows.