This document outlines how “politically exposed persons” (PEPs) have
been categorised for the purposes of Dow Jones Watchlist.
The paragraph headers below all reflect Occupation Categories as listed
on Dow Jones Watchlist.
The list of Occupation Categories on Dow Jones Watchlist:
Heads & Deputies State/National Government
National Government Ministers
Members of the National Legislature
Senior Civil Servants-National Government
Senior Civil Servants-Regional Government
Embassy & Consular Staff
Senior Members of the Armed Forces
Senior Members of the Police Services
Senior Members of the Secret Services
Senior Members of the Judiciary
State Corporation Executives
State Agency Officials
Heads & Deputy Heads of Regional
Government
Regional Government Ministers
Religious Leaders
Political Party Officials
International Organisation Officials
City Mayors
Political Pressure and Labour Group Officials
Other
National NGO Officials
The Occupation Categories have been defined using FATF
Recommendation 6 in conjunction with feedback from founder clients
and industry comment. Care is taken to include only senior PEPs, their
relatives and close associates on Dow Jones Watchlist. The Research
Team works to strict guidelines which define the coverage criteria to be
used for every category and country in the world.
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Heads & Deputies State/National Government
Presidents, Premiers, Chancellors, Prime Ministers and their deputies and royal
heads of state can be found in this category.
Those who have previously been heads of state and no longer hold any political
office come under the Heads & Deputies State/National Government category
with “See Previous Roles” in their Occupation Title. If someone who was once a
head of state now holds a lesser political office, they will be found under the
Occupation Category covering the lesser political office.
National Government Ministers
This category contains a country’s government ministers eg Finance Minister,
Foreign Minister, Secretary of Defense (US) and deputy government ministers
such as Deputy Finance Minister, First Deputy Transport Minister.
In some countries, Canada is one such example, the deputy ministers are civil
service roles and therefore go in the senior civil service category.
For those who have ministerial rank but not a ministerial post eg some Central
Bank governors and some senior armed forces staff, these are to be found in the
Occupation Category that goes with their role and “Ministerial rank” will be
indicated in the Other Roles section on Dow Jones Watchlist.
Members of the National Legislature
This category contains members of the bodies/assemblies making up the national
legislature - whether unicameral, bicameral, tricameral eg members of the House
of Commons (lower house) and House of Lords (upper house) for the UK, House
of Representatives and Senate for the US, members of the State Duma and
Federal Council for Russia, the Bundestag and Bundesrat for Germany and the
Nationalrat and Ständerat for Switzerland.
Members of assemblies like the Loya Jirga in Afghanistan come under Members of
the National Legislature category even though these are one-off assemblies with
a list of attendees – attendees change from one Loya Jirga to next.
Senior Civil Servants–National Government
This category contains the uppermost levels of the civil service. It contains those
in the position of Permanent Secretary in the UK, Staatssekretär in Germany,
Deputy Secretary in the US or equivalent, the top level tier in the civil service,
plus the next level down (this is Director General level in the UK) and, if
available, department heads (the next level down from Director General).
This approach works for countries where structured information is available. For
other countries, where Dow Jones Watchlist relies on news coverage only, names
and occupation titles may arise in the press and it is difficult to assess the exact
seniority of the individual. If they seem suitably senior, they will be included on
Dow Jones Watchlist.
Senior Civil Servants – Regional Government
This category covers heads and senior members of regional civil service
departments. Titles vary depending on the country concerned, but include titles
like Secretary of State for a particular region, General Secretary, Director. Getting
data for the uppermost tiers of regional civil service works for countries where
structured information is available. For other countries, where Dow Jones
Watchlist relies on news coverage only, names may arise in the press and it is
difficult to assess the exact seniority of the individual. If they seem suitably
senior, they will be included on Dow Jones Watchlist.
NB: Not all countries have what would be classified as a regional civil service
system and so may have no entries in this category.
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Embassy and Consular Staff
Ranks included on Dow Jones Watchlist are: Ambassador, Chargé d'Affaires,
Consul General, Minister Counselor, Honorary Consuls.
A country’s Permanent Representative to the UN also comes under this category.
Senior Members of the Armed Forces
Dow Jones Watchlist covers the top post holders and ranks for the army, navy
and air forces. For example for the United States, Dow Jones Watchlist has details
on the following ranks: Admiral, Vice Admiral and Rear Admiral for the Navy and
General, Lieutenant General, Major General and Brigadier General for the Army
and Air Force.
This approach works for countries where structured information is available. For
other countries, where Dow Jones Watchlist relies on news coverage only, names
may arise in the press and it is difficult to assess the exact seniority of the
individual. If their role seems suitably senior, they will be included on Dow Jones
Watchlist. People of lesser rank in some countries have a significant role, often it
is the role rather than the rank that is important.
Where available (this tends to be for developed countries) Dow Jones Watchlist
includes the rank and job title by putting the job title in Occupation Title with
rank in Other Roles.
For less developed countries or where less information is available, the only
details available for Dow Jones Watchlist might be the rank.
Senior Members of the Police Services
Dow Jones Watchlist aims to include the chief of the national police and the chief
of regional police forces as a minimum for each country. For some countries
where information is more readily available Dow Jones Watchlist has been able to
extend coverage. For example, for the UK the ranks of Chief Constable, Deputy
Chief Constable, Assistant Chief Constable and Chief Superintendent are included.
Senior Members of the Secret Services
This category contains the names of senior members of the secret
services/intelligence community as available in directories/press/government
websites.
The nature of this role means there are unlikely to be many entries in this
particular category for each country. Dow Jones Watchlist has over 1,000 people
in this category worldwide.
Senior Members of the Judiciary
Dow Jones Watchlist contains details of judges from a country’s top courts –
Supreme Court, national courts, appeal courts, high court judges but not
magistrates.
Inclusion of an individual in this category on Dow Jones Watchlist is not
determined by whether that person was elected or appointed to a post, but by
the seniority of the role. Differentiation is not made between election or
appointment to the role as this varies from country to country and this
information can be difficult to ascertain for particular roles in particular countries.
State Corporation Executives
This category contains senior executives (supervisory board/board members) of
larger state-owned corporations.
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State Agency Officials
This category contains top officials at the main state agencies including central
banks, state broadcasters, air traffic control bodies and regulatory bodies.
Heads & Deputy Heads of Regional Government
Regional/state prime ministers, presidents, premiers, governors, chief ministers
and their deputies are to be found in this category.
Regional Government Ministers
This category contains ministers in regional government, where these exist. Not
all countries have regional governments for example El Salvador, Japan.
Religious Leaders
This category contains leaders of major faith traditions.
Political Party Officials
This category contains leaders, deputy leaders, directors and members of the
national councils/executives/boards of significant political parties. Note: some
senior party officials hold other, more senior public office and may be found under
another Occupation Category. For example the head of a major party could also
be the Prime Minister of a country. In this case the entry would be under the
category Heads & Deputies State/National Government, not under Political
Party Officials.
International Organisation Officials
The leaders and senior officials of leading international organisations like the
United Nations organisations UNICEF, UNDP and the Arab League, World Customs
Organisation, International Olympics Committee…
City Mayors
This category contains information on the mayors of capitals, mayors of regional
capitals and the mayors of major large cities (over 100,000 inhabitants in
general).
Political Pressure and Labour Group Officials
This category contains leaders and senior officials of interest groups that seek to
influence public policy and legislation in relation to their particular priorities.
These groups may be militant. Labour Group Officials covers trade union officials.
Other
There are two broad groups in this Occupation Category:


Members of the European Parliament
Political power brokers for a particular country but for whom no general
global occupation category applies, for example Tribal Chiefs in certain
African countries.
National NGO Officials
This category covers larger private non-governmental organisations that pursue
activities to relieve suffering, promote the interests of the poor, protect the
environment, provide basic social services or undertake community development.
NGOs depend, in whole or in part, on charitable donations and voluntary service.
Principles of altruism and voluntarism are their key defining characteristics
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