Politically exposed persons (PEPs) under Estonian law – President, members of the Riigikogu, cabinet, party boards, governing bodies of state-owned enterprises and foundations.
The PEP concept comes from § 9¹ of the Money Laundering and Terrorist Financing Prevention Act. The law gives the general definition; the precise list of Estonian offices is set by the responsible minister’s regulation (§ 9¹ subsection 5), which our categories follow. Former PEP status is kept for 12 months after a person leaves office, in line with FATF guidance.
Data is collected from public registers on a daily basis in most cases. Riigikogu and cabinet changes reach the list quickly; board changes at companies and agencies follow once the corresponding Business Register entry takes effect.
§ 9¹. Politically exposed person
(1) A politically exposed person is a natural person who performs or has performed prominent public functions and in respect of whom related risks persist.
(2) Persons performing prominent public functions are deemed to include at least:
(3) Middle- and lower-ranking officials are not deemed politically exposed persons.
(4) A person whom an EU Member State, the European Commission or an international organisation accredited in the EU treats as performing prominent public functions per the European Commission’s published list is also a politically exposed person.
(5) The list of Estonian offices whose holders are deemed politically exposed persons is established by the responsible minister by regulation; nimistu’s categories follow that list.
Source: Riigi Teataja - MLTFPA § 9¹