Posted on by Juan Carlavilla

Andorra and its definition of PEP

Fecha de última actualización: 23/06/2025

Andorra and its definition of PEP Photo by Sasha Plesco

Just like other European countries such as Portugal, Spain, or France, the Principality of Andorra also includes provisions regarding politically exposed persons (PEPs) in its anti-money laundering regulations. These measures, along with Andorra’s AML framework, stem from the Monetary Agreement signed between Andorra and the European Union.

Although the Pyrenean country is not part of the European Union, its geographic location and close ties with neighbors Spain and France made it necessary to sign a Monetary Agreement on June 30, 2011, to regulate the use of the common currency. The main purpose of this Agreement was to allow Andorra to adopt the euro as its official currency and issue euro coins, subject to meeting certain regulatory milestones.

One of these milestones was the proper implementation of EU legal acts and regulations relating to the prevention of money laundering, fraud prevention, and the counterfeiting of both cash and non-cash payment instruments.

The main legal instrument in this area is Llei 14/2017, de 22 de juny on the prevention and fight against money laundering and terrorist financing. Additional guidance is provided by the Regulation applying Law 14/2017 on the same matter.

Article 6.3 of Llei 14/2017 specifies the positions considered to be politically exposed persons. Subsequent sections define PEPs’ family members and close associates. The Regulation further includes individuals holding leadership, management, or supervisory roles in public entities, autonomous bodies, and state-owned enterprises.

Articles 14 and following lay out the general regime applicable to PEPs. These sections establish the need for procedures to determine whether a beneficial owner is a PEP.

They also define the duration of PEP status. Andorran law specifies that once a PEP leaves office, enhanced measures remain in place for at least 12 months.

List of PEPs in Andorra

The public offices that qualify as PEPs under Andorran law include:

  1. Heads of State, Heads of Government, ministers, undersecretaries or secretaries of State;
  2. General councillors or members of other national, international or supranational legislative assemblies;
  3. Consuls general and consuls, finance or urban planning councillors, and equivalent positions in other states;
  4. Members of political party leadership;
  5. Judges of the Superior Court of Justice, supreme courts, constitutional courts or other high judicial bodies whose decisions are generally not subject to appeal;
  6. Members of Audit Courts, foreign audit bodies, boards of central banks or similar institutions;
  7. Ambassadors, chargés d’affaires and senior military officers;
  8. Members of administrative, management, or supervisory boards in public sector entities, autonomous bodies, and state-owned companies;
  9. Directors, deputy directors and board members, or equivalent, of international organizations.

Below are the primary sources Pibisi uses to identify PEPs in Andorra:

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