Who is PEP in Poland? New positions falling within the definition of 2021

Important news for AML departments: The list of Polish PEPs (politically exposed persons) has just been expanded. Since October 31, 2021, new positions have been officially added to the definition of PEP in Poland, and now not only politicians like deputies of Seym or senators are considered as persons for whom more stringent verification procedures should be applied.

Who is PEP in Poland?

Who is PEP? It’s not just a “politician”

The acronym of PEP comes from the term politically exposed person. PEP positions include in general presidents, politicians, judges of the higher courts, officers and members of political party boards. Politically exposed persons are particularly vulnerable to corruption due to their role or position that is considered influential. From October 31, 2021, we have new PEP positions in Poland. From that day, Polish law officially defined mayors, district governors and many smaller positions also as politically exposed persons.

The term PEP is related to the IV AML Directive, which defines due diligence procedures for the so-called obligated institutions, i.e. banks, companies keeping accounting books, auction houses and art galleries. Pursuant to the AML Directive, obligated institutions are required to identify a politically exposed person and implement appropriate procedures that may be defined as “special service”. Importantly, and extremely difficult in the practice of working with data, the obligation to verify PEP also applies to their family members and close associates.

Change in the definition of PEP in 2021 — what new positions have appeared on the list of Polish PEPs?

Previously, it was known that the Polish PEP are certainly deputies, senators, voivods and, inter alia, Supreme Court judges. The positions, however, were not clearly defined. The definition of PEP in Poland was therefore a large field for interpretation (full list of those “standard” positions you can find HERE). This has changed now. The new regulation of the Minister of Finance, Funds and Regional Policy specifies 215 concrete positions and public functions as PEP.

The most important new positions that extend the definition of PEP — list:

Below are the most important new positions of PEP in Poland, which did not necessarily follow the previous definition:

  • Voivodeship marshal and member of the voivodeship board;
  • Head of the commune,
  • City mayor,
  • City president;
  • District governors (so called starosta powiatowy) and members of the district board;
  • Chief Land Surveyor and his deputy;
  • Main Pharmaceutical Inspector and his deputy;
  • Chief Inspector of Commercial Quality of Agricultural and Food Products and his deputy;
  • Chief Inspector of Construction Supervision and his deputy;
  • Chief Inspector of Plant Health and Seed Inspection and his deputy;
  • Chief Inspector of Environmental Protection and his deputy;
  • Chief Labor Inspector and his deputy;
  • Chief Sanitary Inspector and his deputy;
  • Chief Road Transport Inspector and his deputy;
  • Chief Veterinary Officer and his deputy;
  • Chief Financial Discipline Spokesman and his deputy;
  • General Director of the State Archives and his deputy;
  • President of the Chemical Substances Bureau;
  • President of the Central Office of Measures and his deputy;
  • President of the Institute of National Remembrance
  • Commission for the Prosecution of Crimes against the Polish Nation and his deputy;
  • President of the Polish Water National Water Management and his deputy;
  • President and vice-president of the National Atomic Energy Agency;
  • President and vice president of the Polish Space Agency;
  • The President of the Polish Audit Oversight Agency and his deputy;
  • President and vice-president of the Polish Tourist Organization;
  • President and vice-president of the Government Legislation Center;
  • President of the Governmental Agency for Strategic Reserves and his deputy;
  • President and vice-president of the Office of Technical Inspection;
  • President of the Office of Electronic Communications and his deputy;
  • President and vice-president of the Civil Aviation Authority;
  • President of the Management Board of the National Fund for Environmental Protection and Water Management and his deputy;
  • President of the Board of the State Fund for Rehabilitation of Disabled Persons and his deputy;
  • Chairman of the State Commission for the investigation of cases of activities directed against sexual freedom and decency towards a minor under the age of 15 and members of this commission;
  • Chairman of the National Broadcasting Council, his deputy and members of the Council;
  • Chairman and vice-chairman of the Council for Refugees;
  • Chairman and member of the National Media Council;
  • Spokesman for Small and Medium Enterprises and his deputy;
  • Children’s Ombudsman and his deputy;
  • Ombudsman and his deputy;
  • Patient Rights Ombudsman and his deputy;
  • Head of the Office for Foreigners and his deputy;
  • Head of the Office for Veterans and Victims of Oppression and his deputy.

The full text of the regulation and the list of all PEP positions in Poland (available only in Polish) can be found HERE.

Several other known PEP positions in Poland that are already on the list

  • President of the Republic of Poland;
  • Prime Minister;
  • Vice-president of the Council of Ministers;
  • Ministers;
  • Secretaries of State;
  • Under Secretaries of State;
  • Members of Parliament;
  • Senators;
  • Members of the European Parliament;
  • Chargés d’affaires;
  • Officers holding a positions in the armed forces of the Republic of Poland, classified as general (admiral);
  • President of the National Bank of Poland;
  • Head of the Chancellery of the President of the Republic of Poland;
  • General directors of the Prison Service;
  • Chiefs Commanders and Deputies Commanders-in-Chiefs of the State Fire Service;
  • Police Commanders in Chiefs and their deputies;
  • Chiefs Commandants and deputies Commanders-in-Chiefs of the Border Guard;
  • President and vice president of the Patent Office of the Republic of Poland;
  • President and vice president of the Energy Regulatory Office;
  • President and vice president of the Office for Registration of Medicinal Products, Medical Devices and Biocidal Products;
  • Attorney General and his deputy;
  • National Public Prosecutors;
  • Chairmans, Deputies Chairmans and members of the Polish Financial Supervision Authority;
  • Deputies Chairmans of the Polish Financial Supervision Authority.

How to verify that the contractor is a PEP?

Unfortunately, in Poland there is no official central PEP register. Performing all AML activities by obligated institutions, i.e. PEP verification, is an extremely time-consuming task and not so simple at all due to the difficulties in finding appropriate data sources. This is why the most obligated institutions use company information providers to get AML API or Polish PEP API. If you’re looking for one, you can check our Transparent Data PEP database.

More information about the data provider from PEP and sanctions lists — an agile technology company Transparent Data, can be found at:


AML procedures in the case of the contractor’s presence on the PEP list

If the obligated institutions receive proof that their contractor is a politically exposed person, they initiate an additional procedure based on risk analysis. All activities are preventive. Their main goal is to protect the financial sector from legal problems and loss of good repute.

One of the actions organisations undertake for this purpose is accepting a written declaration from such a contractor that they are or are not a PEP. The document is submitted under criminal liability. Banks and other obligated institutions also apply appropriate measures to determine the source of the contractor’s property, which is at his disposal as part of business relationships or transactions.

Moreover, obligated institutions apply appropriate procedures towards PEP even when it ceases to occupy a politically exposed position. The procedures require that appropriate risk measures be taken into account for a period of at least 12 months from the date on which the contractor officially ceases to assume a politically exposed position.



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