Who is a PEP? Financial intelligence unit lists all government roles
The Financial Intelligence Analysis Unit has published a list of all government jobs whose authority and control on vast amounts of money and influence, qualifies them as political exposed persons (PEPs)
The list, drawn up on advice of the National Co-ordinating Committee on Combating Money Laundering and Funding of Terrorism, means that such PEPs have to undergo a more rigorous assessment when their business relations are being process by bankers or notaries, among other professionals.
Subject persons are expected to review PEPs’ ongoing business relationships and any prospective occasional transactions.
The list starts with the highest-ranking members of the Maltese State and government: the President of the Republic, the prime minister and all ministers and parliamentary secretaries, the Speaker of the House, but also all heads of secretariat within any government ministries.
Next come members of the governing bodies of political parties, but limited only to political parties represented in the House of Representatives: top positions such as party leaders and deputy party leaders, CEOs and deputy roles, secretary-generals and assistant secretaries.
The Chief Justice and all Judges serving in the Courts are PEPs, as well as the Governor of the Central Bank of Malta, deputy governors and Central Bank directors, the Auditor General and the Deputy Auditor General.
All ambassadors, chargé d’affaires and high-ranking army officials – the Commander and deputy commander – are listed as PEPs.
Other senior state and government officials listed as PEPs are the head of the civil service, or the principal permanent secretary, the Attorney General and State Advocate, all permanent secretaries, the Ombudsman and other commissioners within the office, the Commissioner of Police and the deputy commissioner, the Commissioner for Revenue, the Security Service head, the Information and Data Protection Commissioner, and the director, chair and depuy chair of the Asset Recovery Bureau.
Also listed as PEPs are a host of high-ranking officials within state-owned enterprises. These comprise members of the administrative, management or supervisory Boards including chairpersons, CEOs, directors of state-owned (50% ownership) enterprises, and other entities were the government has a golden share. These include companies such as Air Malta, Enemalta or even smaller outfits like Projects Malta.
Top-ranking officials of public entities, constitutional bodies and government departments reponsible for licensing or permits that “could potentially generate considerable turnover” are also PEPs: they include the director of the Commerce Department, the chair, CEO and members of the Environment and Resources Authority, the chair, CEO and chief audit officer of the Lands Authority, the chair of the Licensing (Trading) Appeals Board as well as the licensing Board set up under the Real Estate Agents, Property Brokers and Property Consultants Act; the CEOs and chairs of the Malta Digital Innovation Authority (MDIA), the Malta Gaming Authority, the Malta Tourism Authority, Malta Further and Higher Education Authority, Regulator for Energy and Water Services, and Superintendent of Cultural Heritage.
All Transport Malta’s units’ chairs and CEOs, and deputies are PEPs: they include the COO of TM, the registrar general of Shipping and Seamen, the Cos of ports and yachting, harbour master, land transport directorate, transport strategy, corporate services, civil aviation, and marine safety investigations.
All chairs and members of the Planning Authority’s executive council, planning board, planning commissions, and the environmental and planning review tribunal.
PEPs also include the roles of those whose imposition of administrative fines of substantial value has a significant financial effect, such as the chairperson, CEO and members of the authority responsible for regulation and monitoring of the building and construction industry, the Director-General of Customs, the FIAU chairperson and director, the Malta Business Registry’s registrar, the chairs, board members and CEOs of the Malta Communications Authority and the Malta Financial Services Authority.
Also included are those roles who approval high-value contracts and tenders in excess of €250,000, such as the director-general of Contracts, the chair of the Commercial Sanctions Tribunal and General Contracts Committee, the CEO of Infrastructure Malta, and the chairperson of MITA.
All roles involved in the granting of citizenship or residency are PEPs: these include the regulator for granting of citizenship (formerly IIP), and the chairpersons and CEOs of Identity Malta Agency, Komunità Malta, and the Malta Residency Visa Agency.
Chairpersons and CEOs of grant schemes – the Arts Council, the Housing Authority, Malta Enterprise, and the Resource, Recovery and Recycling Agency – are also PEPs.