Is an appointed District Court judge considered a PEP?
Is an elected sheriff considered a PEP?
Is the dispatcher that works at the Sherriff's office considered a PEP?
At what level does being a PEP stop?

Per FFIEC manual, the term “politically exposed person” generally includes a current or former senior foreign political figure, their immediate family, and their close associates.

These categories would not be PEPs.

These categories would not be PEPs

unless they are married to a PEP

Or unless your policy or procedures define them as a PEP.

Thanks, so much, for your help! That is what I thought.

I have an examiner here who insists they are PEPs. Does anyone have any suggestions on how to handle this?

Your examiner is confused by 35k on the SAR, "domestic corruption."

When they came out with the new SAR the ABA went ballistic on this new option, complaining that it would create the concept of a "domestic PEP" and banks would be hovering over local, state, and federal politicos as if they were dictators in some banana republic. Your examiner fulfills the ABA's prophecy.

Just say, "There is no formal guidance on "domestic PEPs" and we do not accept the concept. Also, we would describe some of these people as nothing more than government employees, not "officials." Regardless, we will be interested to read your criticism in the written report."

Please, do not let them get away with this [censored].

I would agree with what Ken said as far as not classifying domestic PEPs and point them to the definition in the exam manual of a PEP. pg 295 of PDF

https://www.ffiec.gov/bsa_aml_infobase/documents/bsa_aml_man_2014.pdf

have an examiner here who insists they are PEPs. Does anyone have any suggestions on how to handle this?

" I am having sort of an issue locating where these customers are to be listed as a PEP so I can change the branch policy of course. Could you show me where it is?"

Translation; you can not possibly believe these are PEPs if so I suggest extra training for all Exam staff.

Thank you for the suggestions and I will follow your advise. I hope this is not an intentional change in the examiner's expectations!

Being in the industry a very long time, I've always referenced the FFIEC guidance on PEPs (=foreign). Interestedly enough, in a recent conversation, it was brought up that FATF 12 references "domestic" PEPs. We had no issues with audit/exam with only addressing foreign PEPs but I did find it interesting that such a reference is out there.

Yes, FATF does reference that. If your operations are only domestic, I would make the argument that you follow the FFIEC's guidance instead of the FATF. The FATF recommendations are just that - recommendations. Unless you are operating in a jurisdictions with more stringent laws/regulations, it would not currently be required.