Posted on by Juan Carlavilla

Finland and its definition of PEP

Finland and its definition of PEP. Photo by András Rátonyi.

Finland, just like other European countries such as France, owes its regulations on anti-money laundering and counter-terrorism financing to the European Directives that have been developed over the years. This is why the definition of a PEP (Politically Exposed Person) provided by the Nordic country is closely tied to this European legal instrument.

Regarding PEPs, Finnish legislation includes this definition in Laki rahanpesun ja terrorismin rahoittamisen estämisestä — Anti-Money Laundering and Counter-Terrorism Financing Act. In Section 11, of Chapter I, Section 2 of the Act, the definition of public officials is provided, along with a list of positions that hold this distinction. This list of positions is further developed by a Decree issued by the Government of Finland. 

The Finnish law defines politically exposed persons as a “natural person who holds or has held a prominent public position.” This definition was added in 2019, after the transposition of the Fifth Directive.

List of PEPs in Finland

There are 10 different categories of positions that qualify as PEPs in Finland. These positions are listed in anti-money laundering regulations and further detailed in the legislative development issued by the Government. The political positions that hold PEP status are:

  1. Head of state, head of government, minister, deputy minister, or vice minister. These roles include:
    • the duties of the president of the republic, the prime minister, and ministers as mentioned in Chapter 5 of the Constitution;
    • the duties of the Secretary of State;
    • the duties of a member of the Åland Provincial Government and the duties of the Governor of Åland.
  2. Member of Parliament. This includes:
    • the duties of a member of parliament;
    • the duties of a member of Åland’s provincial parliament;
    • the duties of a member of the European Parliament.
  3. Member of a political party’s governing body. A political party is defined as one registered in the Party Register, in accordance with the Party Act (10/1969). These roles include:
    • the duties of a member of a political party’s governing body, including the duties of the president and members of the party’s board of directors;
    • the duties of a substitute member of a political party’s executive body.
  4. Member of the Supreme Court, Constitutional Court, or similar judicial bodies whose decisions are final, except in extraordinary cases. These include:
    • the duties of the president of the Supreme Court, legal advisor, and, in military matters, the military member;
    • the duties of the president of the Supreme Administrative Court, legal advisor, environmental expert, and chief engineering advisor;
    • the duties of the president of the labor court, the labor court advisor, and the expert member;
    • the duties of the Chief Justice, Insurance Judge, Chief Medical Judge, and other members and expert members of the Insurance Court;
    • the duties of an assessor in the labor court and insurance court.
    • The duties of members of supreme courts, the Constitutional Court, or other similar judicial bodies also include the duties of a substitute.
  5. Member of the State Audit Office and the highest decision-making body of the State responsible for the financial oversight of the State, corresponding to the State Audit Office.
    • The duties of the State Audit Office and members of the highest decision-making body responsible for the financial oversight of the State, as per Chapter 1, Section 4, paragraph 11(e) of the Anti-Money Laundering Act, are the duties of the Director-General of the State Audit Office.
  6. Member of the Board of Governors of the Central Bank.
    • These duties include those of a member of the Board of Governors of the Bank of Finland.
  7. Ambassador and Chargé d’Affaires. 
    • The duties of an ambassador are those of the head of mission in charge of an embassy, permanent mission, special mission, or consulate general;
    • The duties of a Chargé d’Affaires are described in Article 19.1 of the Vienna Convention on Diplomatic Relations signed on April 18, 1961.
  8. In the Defense Forces, an officer with the rank of general or higher. Relevant roles include:
    • Commander of the Defense Forces, Chief of Staff, General, and Admiral.
  9. Member of the administrative, management, and supervisory body of a wholly state-owned company.
    • These roles include the duties of the chair of the board, board member, CEO, chair of the supervisory board, and member of the supervisory board;
    • The duties of a substitute member and deputy CEO are also included.
  10. Director, Deputy Director, and Member of an international organization. Relevant roles include:
    • The Secretary General, Deputy Secretary General, President, Chair of the Board, and Board member of an international organization;
    • The duties of a substitute member of the aforementioned positions are also included.

Below are the main sources we use at Pibisi to extract the PEPs from Finland:

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