PEP Policy

Under Estonian legislation, we’re required to know whether our customers are considered PEPs.

However, being a PEP does not automatically prevent you from being our customer. We just need to know.

A politically exposed person (PEP) is an individual who is, or has been in the past 12 months, entrusted with a prominent public function. Family members and close business associates of PEPs are also considered PEPs themselves.

  • Head of State, Head of Government, Minister, Deputy or Assistant Minister
  • A Member of Parliament or of similar legislative bodies
  • A member of the governing bodies of political parties
  • A member of the Supreme Court, the Constitutional Court, or any other similar judicial body, whose decisions may not, except in exceptional cases, be appealed
  • A member of the Supreme Audit Institution of the Court of Auditors and the State Audit Office
  • A member of the Governing Board of the Central Bank
  • Ambassador or trustee
  • At least as a military officer in the Armed Forces
  • A member of the administrative, management, and supervisory body of a wholly-owned State enterprise
  • Director, deputy director, and board member of international organizations
  • Member of the European Commission (EC)
  • State secretary

Due to the regulations established by the money laundering and terrorism financing prevention legislation, the Company will not provide Services to politically exposed persons, persons included in the international sanctions list (https://www.sanctionsmap.eu/#/main), residents of high-risk third countries (http://www.fatf-gafi.org/countries/#high-risk), and persons mentioned in the database https://www.e-krediidiinfo.ee/sanktsioonid.

By ordering Services from us, the Client confirms whether he qualifies or does not qualify to be listed in the above list. We have the right to terminate the Services offered at any time and immediately if it becomes apparent that false or falsified information has been provided to us.