Politically Exposed Person (PEP) C6 Intelligence Approach to PEP Definition The general PEP Definition of C6 Intelligence Information Systems Ltd. (C6) is based on the FATF version: • current or former senior official in the executive, legislative, administrative, military, or judicial branch of a foreign government (elected or not) • a senior official of a major foreign political party • a senior executive of a foreign government owned commercial enterprise, being a corporation, business or other entity formed by or for the benefit of any such individual • an immediate family member of such individual; meaning spouse, parents, siblings, children, and spouse's parents or siblings • any individual publicly known (or actually known by the relevant financial institution) to be a close personal or professional associate. While such definition is a valid source of mandate for financial institutions to seriously consider, in order to comply with relevant regulations, C6 considers it not sufficiently elaborate for its clients to conveniently refer to the PEP verification process in a comprehensive approach. To address this issue, C6 has set up in-house PEP Categorisation guidelines that serve as the research framework for its analysts to follow consistently throughout their systematic research and ad hoc due diligence investigations. While several categories have to be treated with discretion in certain contexts, the general guidelines should cover most governance systems spanning all jurisdictions in the world. In accordance with the designated risk levels, the categories are divided into different priority groups, which also form the ‘pecking order’ in C6’s systematic data development and maintenance: Priority 1 • Heads of State and Gov't • Heads of Executive Branch (Central Level) - Ministers / Deputy / Assistant Ministers • High-ranking Civil Servants of Executive Branch (Central Level) • Heads of Military, Security and Publish Security Services • Members of the Legislative Branch (National Level) • Leaders of Political Party / Movement • Members of Judiciary Branch (Judges of Supreme Courts) • Heads of Courts of Auditors, Financial / Monetary Regulatory Bodies • Board Members of Central Bank or Monetary Authority • Heads of Diplomatic Missions to foreign countries and IGOs • Heads of Foreign Missions • Heads of IGOs

1. PEPs & Sanctions Information
C6 Intelligence Information Systems Ltd
June 2011
(Updated August 2012)
PEPs & Sanctions C6 Intelligence Information Systems Ltd
1

2. Politically Exposed Person (PEP)
C6 Approach to PEP Definition
The general PEP Definition of C6 Intelligence Information Systems Ltd. (C6) is based on the FATF version:
• current or former senior official in the executive, legislative, administrative, military, or judicial branch of a
foreign government (elected or not)
• a senior official of a major foreign political party
• a senior executive of a foreign government owned commercial enterprise, being a corporation, business
or other entity formed by or for the benefit of any such individual
• an immediate family member of such individual; meaning spouse, parents, siblings, children, and
spouse's parents or siblings
• any individual publicly known (or actually known by the relevant financial institution) to be a close personal
or professional associate.
While such definition is a valid source of mandate for financial institutions to seriously consider, in order to comply
with relevant regulations, C6 considers it not sufficiently elaborate for its clients to conveniently refer to the PEP
verification process in a comprehensive approach.
To address this issue, C6 has set up in-house PEP Categorisation guidelines that serve as the research framework
for its analysts to follow consistently throughout their systematic research and ad hoc due diligence investigations.
While several categories have to be treated with discretion in certain contexts, the general guidelines should cover
most governance systems spanning all jurisdictions in the world. In accordance with the designated risk levels, the
categories are divided into different priority groups, which also form the ‘pecking order’ in C6’s systematic data
development and maintenance:
PEPs & Sanctions C6 Intelligence Information Systems Ltd
2

3. Priority 1
• Heads of State and Gov't
• Heads of Executive Branch (Central Level) - Ministers / Deputy / Assistant Ministers
• High-ranking Civil Servants of Executive Branch (Central Level)
• Heads of Military, Security and Publish Security Services
• Members of the Legislative Branch (National Level)
• Leaders of Political Party / Movement
• Members of Judiciary Branch (Judges of Supreme Courts)
• Heads of Courts of Auditors, Financial / Monetary Regulatory Bodies
• Board Members of Central Bank or Monetary Authority
• Heads of Diplomatic Missions to foreign countries and IGOs
• Heads of Foreign Missions
• Heads of IGOs
Priority 2
• Heads of Executive/Legislative/Judicial Branches (Regional Level: Metropolitan / Provincial / State /
County…)
• Important State-owned/-run Enterprises - Admin., Supervisory, Management Bodies
• Constitutional Courts and Courts of Appeal
• Family Associations of Priority 1 level PEPs (directly linked)
1. Children / Parents / Their Spouses
2. Siblings / Their Spouses
3. Grandparents / - children; cousins / Their Spouses
4. Spouse / Relatives of the Spouse
Priority 3
• Heads of City/Town/Local-level Administration
• Heads of Trade/Labour Unions, Religious Groups/Organisations, Influential NGOs, etc.
• Ombudsmen
• Close Personal/Professional Associates of Priority 1 level PEPs
• Historical Priority 1 level PEPs and Associates
PEPs & Sanctions C6 Intelligence Information Systems Ltd
3

4. PEP Data Resources
Our sources include official sites such as government or national assemblies and foreign offices.
Systematic Data-entry:
• CIA World Leaders
• CIA World Factbook
• Rulers articles and other databases continually monitored to additional information
• Gov’t/Official websites covering all levels of PEPs
• Other useful open sources, e.g. those independent from the state control
Regular Updates:
• Selected media websites for regular (daily) media checks
Where English sources prove insufficient to account for the personal traits and affiliations of certain PEPs, foreign
sources (in foreign/local languages) would be relied upon to obtain fresh information and bridge the gaps between
inconsistent information.
PEPs & Sanctions C6 Intelligence Information Systems Ltd
4

5. Sanctions
All global sanction lists are monitored half hourly and any updates/ releases are updated in the C6 database within
an hour of release. Also, our ongoing reviewing and updating processes ensures the highest level of sanction data
available at all times.
Sanctions Coverage
United Kingdom (UK): HM Treasury
• Consolidated list of financial sanctions targets (Asset Freeze Target List)
• Current Regimes
- Afghanistan
- Al-Qaida
- Belarus
- Burma/Myanmar (Suspended)
- Democratic Republic of Congo
- Egypt
- Eritrea
- Federal Republic of Yugoslavia & Serbia
- Iran (Human Rights)
- Iran (Nuclear Proliferation)
- Iraq
- Ivory Coast
- Lebanon and Syria
- Liberia
- Libya
- North Korea (Democratic People’s Republic of Korea)
- Republic of Guinea-Bissau
- Somalia
- Sudan
- Syria
- Terrorism and terrorist financing
- Tunisia
- Zimbabwe
• Investment Ban List (suspended until 30th April 2013)
PEPs & Sanctions C6 Intelligence Information Systems Ltd
5

6. United States (US): Department of the Treasury - Office of Foreign Assets Control (OFAC)
• Specially Designated Nationals (SDN) List
• OFAC Sanctions Programs
- Balkans-related Sanctions
- Belarus Sanctions
- Burma Sanctions
- Cote d’Ivoire (Ivory Coast)-related Sanctions
- Counter Narcotics Trafficking Sanctions
- Counter Terrorism Sanctions
- Cuba Sanctions
- Democratic Republic of the Congo-related Sanctions
- Iran Sanctions
- Iraq-related Sanctions
- Former Liberian Regime of Charles Taylor Sanctions
- Lebanon-related Sanctions
- Libya Sanctions
- Non-Proliferation Sanctions
- North Korea Sanctions
- Rough Diamond Trade Controls
- Somalia Sanctions
- Sudan Sanctions
- Syria Sanctions
- Transnational Criminal Organizations
- Yemen Related Sanctions
- Zimbabwe Sanctions
US: Department of State - Bureau of International Security & Non-Proliferation Sanctions
• Nonproliferation Sanctions
- Iran and Syria Nonproliferation Act
- Iran Nonproliferation Act of 2000
- Iran, North Korea, and Syria Nonproliferation Act Sanctions (INKSNA)
- Sanctions for the Transfer of Lethal Military Equipment
- Chemical and Biological Weapons Sanctions Laws
- Missile Sanctions Laws
- Iran-Iraq Arms Nonproliferation Act of 1992
- Executive Order E.O. 12938
- Executive Order E.O. 13382
PEPs & Sanctions C6 Intelligence Information Systems Ltd
6

7. United Nations (UN): Security Council Committees
• Resolutions 751 (1992) & 1907 (2009) – Somalia & Eritrea
- Arms Embargo (Consolidated List)
- Travel Ban (Consolidated List)
- Assets Freeze (Consolidated List)
• Resolution 1267 (1999) & 1989 (2011)
- Al-Qaida and associated Individuals and Entities
- Consolidated List
• Resolution 1518 (2003) – Iraq and Kuwait
- List of Individuals
- List of Entities
• Resolution 1521 (2003) – Liberia
- Travel Ban List
- Assets Freeze List
• Resolution 1533 (2004) - Democratic Republic of the Congo
- Consolidated Travel Ban and Assets Freeze List
• Resolution 1572 (2004) – Cote d'Ivoire
- Consolidated Travel Ban and Assets Freeze List
• Resolution 1591 (2005) – Sudan
- Consolidated Travel Ban and Assets Freeze List
• Resolution 1718 (2006) – Democratic People’s Republic of Korea
- List of Designated Entities, Goods and Individuals
• Resolution 1737 (2006) - Iran
- Consolidated Travel Ban and Assets Freeze List
• Resolution 1970 (2011) – Libyan Arab Jamahiriya
- Consolidated Travel Ban and Assets Freeze List
• Resolution 1988 (2011) – Taliban and associated Individuals and Entities
• Resolution 2048 (2012) – Guinea-Bissau
- Consolidated Travel Ban and Assets Freeze List
PEPs & Sanctions C6 Intelligence Information Systems Ltd
7

8. European Union (EU):
• Consolidated list of persons, groups and entities subject to EU financial sanctions
• Restrictive Measures (Sanctions) in Force
- Afghanistan
- Al Qaeda
- Belarus
- Bosnia and Herzegovina
- Burma / Myanmar
- China
- Democratic Republic of Congo
- Cote d’Ivoire / Ivory Coast
- Egypt
- Eritrea
- Republic of Guinea (Conakry)
- Guinea-Bissau
- Haiti
- Iran
- Iraq
- Democratic People’s Republic of Korea (North Korea)
- Lebanon
- Liberia
- Libya
- Moldova
- Serbia and Montenegro
- Somalia
- South Sudan
- Sudan
- Syria
- Terrorist Groups (Foreign Terrorist Organisations)
- Tunisia
- USA (United States of America)
- Yugoslavia (Serbia and Montenegro)
- Zimbabwe
Australia: Australian Transaction Reports and Analysis Centre (Austrac)
• Financial Sanctions (under Information Circulars)
PEPs & Sanctions C6 Intelligence Information Systems Ltd
8