Like other European states, such as Portugal, France, and the Netherlands, Sweden also defines the concept of politically exposed person within its regulatory framework for prevention. Like its European counterparts, this framework is influenced by the recommendations of the FATF and European directives that have shaped Swedish legislative development.
Swedish regulations define PEPs in the Lag (2017:630) om åtgärder mot penningtvätt och finansiering av terrorism — Act (2017:630) on Measures Against Money Laundering and Terrorist Financing. This law incorporates many European transpositions implemented by the Nordic state and serves as a cornerstone of Sweden’s anti-money laundering and counter-terrorism financing framework.
Article 9 of the regulation outlines the roles considered as politically exposed persons in Sweden. The following article also defines family members and associates of politically exposed persons.
Under Swedish law, a family member of a politically exposed person includes the spouse, de facto partner, cohabitant, children and their spouses, de facto partners or cohabitants, and parents.
A known associate is defined as a person with close business ties to a politically exposed person.
Additionally, the Scandinavian regulation includes a section dedicated to the legal regime governing relations with this category of clients. It specifies that politically exposed persons are considered high-risk clients, requiring thorough investigations during the identification process. Furthermore, Swedish regulations mandate the following:
- Take necessary measures to verify the source of assets,
- Apply strict ongoing monitoring of the business relationship,
- Obtain senior management approval to proceed with the business relationship.
List of PEPs in Sweden
Public positions that qualify as PEPs under Swedish regulations include:
- Heads of state or government, ministers, deputy ministers, and assistant deputy ministers
- Members of parliament and similar legislative bodies
- Members of the governing bodies of political parties
- Justices of the Supreme Court, Constitutional Court, or other high-level judicial bodies whose decisions are generally not subject to further appeal except in exceptional cases
- Senior officials in audit authorities and members of central bank governing bodies
- Ambassadors, heads of mission, and high-ranking officers in the armed forces
- Members of the management, governing, or supervisory boards of state-owned enterprises
- In an international organization context: directors, deputy directors, board members, or holders of equivalent positions.
According to the list of roles published by the European Commission in compliance with Article 20 bis of the Directive 2015/849, the roles include:
- Heads of State (Statschefer),
- Heads of Government (regeringschefer),
- Ministers (ministrar),
- Deputy Ministers (vice ministrar),
- Secretaries of State (biträdande ministrar),
- Members of Parliament (parlamentsledamöter),
- Members of similar legislative bodies (ledamöter av liknande lagstiftande organ),
- Members of political party governing bodies (ledamöter i styrelsen för politiska partier),
- Judges of the Supreme Court (domare i högsta domstol),
- Judges of the Constitutional Court (domare i konstitutionell domstol),
- Magistrates of other high-level judicial bodies whose decisions are subject to appeal only in exceptional cases (domare i andra rättsliga organ på hög nivå vilkas beslut endast undantagsvis kan överklagas),
- Senior officials at audit authorities (högre tjänstemän vid revisionsmyndigheter),
- Members of central bank governing boards (ledamöter i centralbankers styrande organ),
- Ambassadors (ambassadörer),
- Heads of Mission (beskickningschefer),
- High-ranking military officers (höga officerare i försvarsmakten),
- Members of the management, governing, or supervisory boards of state-owned enterprises (personer som ingår i statsägda företags förvaltnings-, lednings- eller kontrollorgan),
- In international organizations:
- Global Water Partnership Organization (GWPO) – Executive Secretary
- International IDEA – Secretary-General
- CBSS Secretariat – Head of Secretariat (Director-General)
- NDPHS Secretariat – Director
- World Maritime University – Rector (President) and Vice-Rector (Vice-President)
- European Spallation Source ERIC – Director-General
The following sources are those in the Pibisi database:
- Riksdagen Website of the Kingdom of Sweden
- Government Website of the Kingdom of Sweden
- Royal House Website of the Kingdom of Sweden
- Central Bank Website of the Kingdom of Sweden
- National Audit Office Website of the Kingdom of Sweden
- Government Website of the Kingdom of Sweden
- Armed Forces Website of the Kingdom of Sweden
- Supreme Court Website of the Kingdom of Sweden
- Socialdemokraterna Political Party Website
- Moderata samlingspartiet Political Party Website
- Sverigedemokraterna Political Party Website
- Centerpartiet Political Party Website
- Kristdemokraterna Political Party Website
- Liberalerna Political Party Website
- Miljöpartiet de Gröna Political Party Website
- Feministiskt Initiativ Political Party Website
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