In March 2026, the Superintendency of Non-Financial Entities (SSNF) published a comprehensive guide on the identification and treatment of Politically Exposed Persons (PEPs). The guide clarifies the obligations applicable to non-financial obligated entities by setting out clearer standards for the identification, classification, and ongoing monitoring of PEPs, as well as their close family members and close associates.
The guide was issued via Resolution No. S-008-2026, dated 24 February 2026, and published in the Official Gazette on 20 March 2026. Its objective is to strengthen the internal procedures and controls in line with the requirements of Law 23 of 2015, for the prevention of money laundering, terrorist financing, and the financing of the proliferation of weapons of mass destruction.
Beyond providing a conceptual framework, the resolution serves as a practical regulatory reference detailing the enhanced due diligence measures that must be applied in commercial or business relationships involving PEPs, raising the standard for compliance and ongoing supervision.
Key Features of the Guide
Expanded, non-exhaustive definition of PEP
The guide provides a more detailed list of public functions and roles that may qualify an individual as a PEP. However, it clarifies that this list is illustrative and not exhaustive, so Non-Financial Obligated Entities (NFOs) must evaluate each case individually and classify any individual as a PEP where the characteristics established in the resolution are met.
The list of qualifying positions are detailed in Annex 1 of the resolution and is intended to support the design and operation of internal classification, risk assessment and control processes.
Scope extended to the PEP’s immediate circle
The regulatory framework expressly extends enhanced scrutiny to individuals within PEP’s immediate environment, including:
- Close family members, such as spouse, parents, siblings, and children
- Close associates: people with the capacity to carry out financial, commercial, or any other type of transactions on behalf of a PEP
- Trusted individuals who maintain close, ongoing, and verifiable ties with a PEP and who, by virtue of that relationship, can influence the PEP, act on their behalf, facilitate the management of assets or resources, or serve as an intermediary in transactions
This approach broadens the scope of analysis and reinforces the need for a comprehensive risk assessment that goes beyond the PEP alone.
Mandatory enhanced due diligence
NFOs must apply enhanced due diligence measures in their dealings with PEPs, which includes:
- In-depth analysis of the source of funds and source of wealth, including financial activities and transactions
- Ongoing monitoring of transactions and activities
- Updating of client information and documentation at least once a year
- Verification of information provided by the client through open and reliable sources
Post-tenure monitoring
Control measures are not limited to the period during which the individual holds public office. The guidelines establish that monitoring must continue from the PEP’s appointment and for a period of two years after the individual ceases to hold the relevant public function.
Identification of red flags
The resolution highlights the importance of paying particular attention to transactions that exhibit recognised red flags, due to their potential link to activities requiring further analysis or reporting under the framework for the anti money laundering, counter terrorist financing and proliferation financing framework.
Some examples of red flags, as indicated in the resolution, are:
- Questionable background (complaints, investigations, sanctions related to prior offenses)
- Atypical transactional behavior (participation in unusual transactions or those exhibiting suspicious characteristics)
- Use of complex corporate structures
- Reliance on third-party intermediaries
- Reluctance to provide information
- Elevated geographic risk
- Role and level of influence associated with the public role held
- Source of wealth linked to highly vulnerable sectors
Risk-based approach
Each NFO must reinforce the adoption of a risk-based approach as a cross-cutting principle of compliance and apply the required controls in accordance with the specific risk profile of the PEP relationship, ensuring that higher risk relationships are subject to proportionately stronger oversight.