Definition
A Politically Exposed Person (PEP) is any natural person who holds or has held, within the last 5 years, relevant public offices, positions, or functions in Brazil or abroad, as well as their representatives, family members, and close associates.
The definition is primarily established by BACEN Circular No. 3,978/2020 and CVM Resolution No. 50/2021, grounded in Law No. 9,613/1998 (the Anti-Money Laundering Law) and the recommendations of FATF/GAFI.
Who is considered a PEP?
Circular 3,978 and Decree No. 10,029/2019 include, among others:
Heads of State and government (President, Governors, Mayors)
Ministers, State Secretaries, and equivalents
Members of the Legislative Branch (Senators, Representatives)
Members of the Judiciary and the Public Prosecution Service
Directors of state-owned companies, public agencies, and foundations
Senior officers of the Armed Forces and Police
Leaders of political parties
Members of the boards of directors and supervisory boards of public entities
Extension: first-degree family members (spouse, domestic partner, children, parents) and persons with a close relationship (business partners, representatives) are also treated as PEPs.
The 5-year period runs from the date the person left office.