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A politically exposed person (PEP) is an individual who holds, or has held, a prominent public function and who, because of that position, presents a higher exposure to bribery and corruption. If you are asking what a politically exposed person in Mauritius is and what your company must do about one, the short answer is this: a PEP is not forbidden as a client or shareholder, but the relationship calls for more scrutiny than an ordinary one.
The obligation sits within the anti-money laundering framework described in AML/CFT compliance for Mauritian companies. It falls on every reporting person, and the FIAMLA places the Company Service Provider among the regulated professions, with the Registrar of Companies as its regulatory body. Your own company may also be asked for PEP information by its bank or its corporate service provider.
This page is general information, not advice. How a particular person is classified, and which measures follow, depends on the facts and on the current wording of the law and guidance. Have a qualified adviser review any borderline case.
Who is treated as a PEP
International standards, which Mauritian guidance follows, describe PEPs through three layers. Always check the current FIAMLA text and the FIU and supervisor guidance for the precise definition that applies to you.
The public office holder
The core group is made up of people entrusted with a prominent public function. Typical examples:
- heads of state or government, ministers and senior political figures;
- members of the legislature and senior officials of political parties;
- senior judges and members of high-level judicial or prosecuting bodies;
- senior military officers and heads of state-owned enterprises;
- ambassadors and other senior diplomatic staff;
- senior figures of an international organisation.
Domestic, foreign and international-organisation PEPs
The same role can carry different risk depending on where it is held. A foreign PEP is normally treated as higher risk by default. A domestic PEP, or a person who holds a senior role in an international organisation, is generally assessed on the risk the relationship actually presents. Do not assume that "domestic" means "low".
Family members and close associates
The category does not stop with the office holder. Spouses, partners, children, parents and siblings, as well as people known to share beneficial ownership of a legal entity or to have a close business relationship, are treated in the same way. A company can therefore have a PEP risk even when no director or shareholder holds public office.
When does someone stop being a PEP?
Leaving office does not erase the risk at once. The usual approach is to keep treating a former office holder as a PEP until a documented risk assessment concludes that the heightened exposure has genuinely fallen away. That decision, and the reasons for it, belong on the file.
Where PEPs appear in a company's life
PEP status can surface at several moments, not only at onboarding.
| Situation | Who to check | Why it matters |
|---|---|---|
| Opening a bank account or taking on a corporate service provider | Directors, shareholders, signatories | The provider must apply its own checks before acting |
| Entering a new shareholder or director | The incoming person and their ultimate owner | Ownership changes can introduce a PEP mid-relationship |
| Updating the beneficial ownership register | Each beneficial owner | A PEP behind a holding vehicle is easy to miss |
| Taking a large payment or loan | The counterparty and its owners | Source of funds becomes harder to explain |
| Annual review | All of the above | Status changes: elections, appointments and resignations |
What the law asks of you
The FIAMLA requires each reporting person to identify, assess and understand its money laundering, terrorist financing and proliferation financing risks. That means looking at clients, geographic areas, products, services, transactions and delivery channels, and fixing the level of mitigation accordingly (section 17, as amended by Act 3 of 2026). Part IV of the FIAMLA was amended with effect from 18 April 2026, including the rules on suspicious transaction reporting and risk assessment.
PEPs are one risk factor inside that assessment. Your business risk assessment should say how PEP exposure is detected, who decides, and what follows. A policy that mentions PEPs in a single line, without a procedure behind it, will not stand up to a supervisor's review.
Section 17H adds a geographic layer: the Minister may, on the recommendation of the National Committee, designate as high risk a jurisdiction identified by the FATF as having strategic deficiencies, and enhanced due diligence then applies to transactions involving that country. A foreign PEP connected to such a country sits in the highest-risk category.
PEP screening step by step
Screening is the practical routine that finds PEPs. It is distinct from checking sanctions lists, which is covered separately in sanctions screening for Mauritius companies.
- Collect the identity data
Full name, date of birth, nationality, residential address and the role or occupation, for every individual in the structure.
- Ask the direct question
Put a PEP declaration in the onboarding form, covering the person, close family and close associates.
- Screen against a reliable database
Run the names through a recognised PEP data source and keep a dated record of the result.
- Review each hit
Confirm whether it is the same person, which function applies and whether the role is current.
- Classify and decide
Record the risk rating, apply enhanced measures where needed and obtain the required internal approval.
- Monitor
Re-screen on a defined cycle and when a trigger event occurs.
Names alone are a weak basis. Common names produce false hits, and spelling variants across languages produce misses. Use date of birth and nationality to discriminate, and keep the reasoning for each cleared hit.
Enhanced due diligence for a PEP
Enhanced due diligence (EDD) goes beyond the standard customer due diligence described in the KYC checklist for corporate clients. The usual components are:
- Senior management approval. A PEP relationship should not be opened or continued without sign-off at a senior level, recorded in writing.
- Source of wealth and source of funds. Establish how the person built their assets and where the money in this relationship comes from. The page on source of funds and source of wealth explains what evidence is usually enough.
- Understanding the ownership chain. Trace the structure to the natural person who ultimately owns or controls it, and record every step.
- Purpose of the relationship. Document why the PEP needs a Mauritian company, what activity is expected and what volumes are plausible.
- Ongoing enhanced monitoring. Watch transactions against the expected profile, with lower thresholds for questioning unusual activity.
Decision aid: do enhanced measures apply?
Is the individual, a family member or a close associate a current or former holder of a prominent public function?
Has a documented assessment concluded that the exposure is no longer material?
Is the client linked to a jurisdiction designated as high risk?
How often to review a PEP file
The law sets the principle, not a single calendar. Review frequency follows the risk rating you assign in your risk assessment, and it should be written in your procedures. In practice:
- a PEP relationship is reviewed more often than a standard one, and at least as often as any other high-risk relationship;
- a review is also triggered by events: a change of office, a new directorship, a change in the ownership chain, an unusual transaction, adverse media or a request from a bank;
- every review leaves a trace: date, who carried it out, what was checked and what was decided.
The exact interval is a matter for your compliance officer and your Money Laundering Reporting Officer. Fix it once, apply it consistently and be able to explain it. The compliance calendar is a convenient place to schedule the dates.
When a PEP link raises suspicion
Being a PEP is not in itself a reason to report. A report is triggered by suspicion. If your review turns up something that does not add up, such as funds without an explanation or a refusal to supply documents, you must file a suspicious transaction report with the FIU. Under section 14 of the FIAMLA, a reporting person or auditor must report as soon as they become aware of the suspicion, and no later than 5 working days after it arises. The procedure is set out in suspicious transaction reports in Mauritius.
Do not tell the person concerned that a report is being made.
What can go wrong
Two sets of penalties are worth knowing about.
- A reporting person, or its officer, employee or agent, who knowingly or without reasonable excuse fails to comply with sections 17 to 17G of the FIAMLA, destroys a required record or facilitates a transaction under a false identity faces a fine of up to Rs 10 million and imprisonment of up to 5 years.
- Knowingly providing false customer due diligence information carries a fine of up to Rs 500 000 and imprisonment of up to 5 years.
The wider picture is in penalties for failing anti-money laundering duties.
PEP review checklist
- A PEP question appears in the onboarding form, covering family and close associates
- Every director, shareholder, signatory and beneficial owner has been screened
- Each hit has been reviewed and the outcome recorded
- Senior management approval is on file for each confirmed PEP
- Source of wealth and source of funds are documented
- The ownership chain is traced to the natural person
- The review interval is set and entered in the calendar
- Trigger events are defined and staff know to escalate them
- Training covers PEP recognition for those handling client files
FAQ
Is it illegal to have a PEP as a shareholder or director?
No. PEP status is a risk factor, not a bar. What changes is the level of scrutiny: senior approval, evidence of the origin of wealth and funds, and closer monitoring. A company that cannot obtain that evidence may find that a bank or provider declines the relationship.
Does a former minister still count as a PEP?
Generally yes, for a period after leaving office. The risk is reassessed rather than switched off automatically. Record why you consider the exposure to have ended, and keep the file open to review.
Is a PEP's brother or business partner also a PEP?
Family members and close associates are treated alongside the office holder. They are classified on the basis of the relationship, and the same enhanced measures usually apply.
Does a small company with one director need PEP screening?
The duty belongs to reporting persons, such as the corporate service provider or the bank, but they will ask your company the PEP questions. A small company should still answer accurately and keep its own register of owners up to date. See compliance for a small private company.
Who carries out the screening if I use a service provider?
The provider has its own regulatory duties and will screen. That does not remove your responsibility to give correct information and to tell the provider promptly of changes. The guide on how to choose a corporate services provider covers what to ask.
Can I rely on a free internet search?
A search can supplement the process, but it is a weak substitute for a reliable data source. Keep a dated record of what was searched and found.