As with the OFAC SDN lists, can a complete list of PEP's be found on the internet?

No. Nope. Nyet. Non......

I did find it on the net but can't remember where. It must have been a government site. It was broken down by Country and listed heads of governments, military people, etc. I haven't had to look for over a year but if I find it in my files I'll let you know, but it was out there before, perhaps not now, but I can't imagine they would take it away.

It would be a bad idea to depend on that list as a PEP list. Here's why: From that list, you may know who the senior defense official for Chile is, let's say. So, in the unlikely event that he strolls into a branch of your bank, you're covered. But, what about his bodyguard, his assistant, his wife, his domestic business partners, his adult children, his brothers, and so on. They aren't on a list you can get off the internet.

AML Barbarian is correct on this. It's difficult to rely on any list that may be out there as there is a lack of available and useful identity information about PEPs around the world. From Tahdah's description of the list, it sounds like they may have seen the list of heads of state and cabinet members on the CIA website.

Your first line of defense in identifying PEPs is your customer due diligence, i.e., asking appropriate questions that will help you decide if the customer is, perhaps, a PEP. Any lists out there on the Web might help verify that. AR.

The other issue with a "PEP" list is the same one you have with the OFAC list - the issue of false positives. So a list is really only for guidance in helping identify potential PEP's, but it does not take the place of UNDERSTANDING who your customer is and what they are about when you open the account.

I was at an institution that went all-aquiver because a loan applicant had the same name as a person on one of the "PEP" lists. The PEP in question was the minister of finance for some country, and the applicant was all of 23 years old having just graduated from college and trying to get a "first time buyer" loan.

After talking to former collegues, I believe that I got the list on MoneyLaundering.com (I forgot that I subscribed to that site). And Bonnie you are right, it's a guide just like all of the other lists in my opinion because there is room for error like same names, changing policies/politics, etc. The site I've listed is kind of a teaser. In order to get all of the info you have to subscribe to it, but you can go look and see that they have a ton of PEP info that you can look into.

Anon, what type of questions would you ask at account opening that would identify an individual as a PEP?

Are you a U.S. resident?
If not, what is your country of residence?
What do you do for a living?
What is your source of income?
How much do you think you will be maintaining in balances?
Do you expect to send or receive foreign wire transfers?

Take a look at those NRA accounts that have a significant amount involved in transactions. The smaller the average transaction volume (in terms of dollar value), the less likely you have a PEP issue.