Fecha de última actualización: 10/09/2025
Croatia, like its European counterparts such as Germany, Italy, or France, also introduces the concept of a politically exposed person (PEP) into its legal framework. This regulation stems from the initiatives promoted by the FATF and the regulatory developments established by the European Directives.
The Croatian legislation defines PEPs in the Act Zakon o sprječavanju pranja novca i financiranja terorizma. This legal provision is one of the fundamental pillars for preventing money laundering and terrorist financing in Croatia. The law transposes the various European Directives enacted over the years.
Article 46 of the Croatian regulation defines as family members of politically exposed persons: the spouse, de facto partner, or common-law partner; children and their respective spouses; and the parents of the politically exposed person.
It defines close associates as: natural persons who jointly hold beneficial ownership of a legal entity, trust, or similar arrangement with a PEP; and natural persons who are the sole owners of a legal entity established for the benefit of a PEP.
Paragraph 3 of Article 46 provides a detailed list of positions that the Croatian State considers to be politically exposed persons. Later, in the list issued by the European Commission under Article 20 bis of Directive 2015/849, the Republic of Croatia specifies in detail which positions and offices qualify as PEPs.
Croatian law defines a PEP as “any natural person who is or has been entrusted with a prominent public function in a Member State or a third country during at least the past 12 months, including their immediate family members.”
List of PEPs in Croatia
The public offices that hold the status of PEP in Croatia include:
- President of the Republic of Croatia
- Prime Minister
- Ministers
- State Secretaries
- Deputy Ministers / Heads of Administrative Organizations
- Members of the Croatian Parliament (Hrvatski sabor)
- Members of the governing bodies of political parties:
- Members of the party presidency
- Members of the party management committees
- Judges of the Supreme Court (Vrhovni sud) or Constitutional Court (Ustavni sud), or other judicial officials whose decisions are not subject to appeal except in exceptional circumstances:
- President and judges of the Supreme Court
- President and judges of the Constitutional Court
- President and judges of the High Administrative Court (Visoki upravni sud)
- President and judges of the High Commercial Court (Visoki trgovački sud)
- President and judges of the High Misdemeanour Court (Visoki prekršajni sud)
- Governor, Deputy Governor, and Vice-Governors of the Croatian National Bank [Hrvatska Narodna Banka (HNB)]
- Ambassadors, Extraordinary and Plenipotentiary Ambassadors
- Heads of mission ad interim
- Senior military personnel:
- Brigadier General
- Rear Admiral
- Major General
- Colonel General
- Corps General
- Army General / Air Force General
- Admiral
- Rear Admiral
- Vice Admiral
- Fleet Admiral
- Members of the management, supervisory, and administrative boards, as well as chairs and directors of companies with majority or total state ownership
- Directors, deputy directors, board members, and equivalent officers in international organizations:
- Secretary of the International Sava River Basin Commission
- Head of the WHO Office in the Republic of Croatia
- Head of the UNHCR Office in the Republic of Croatia
- Head of the IOM Office in the Republic of Croatia
- World Bank Office – Director
- UNICEF – Head of Office
- Mayors and Deputy Mayors
- City Mayors and Deputy City Mayors
- County Prefects and Deputy Prefects
Below we detail the main sources used by Pibisi to identify Croatian PEPs:
- Website of the Commission for Conflict of Interest Decisions (Povjerenstvo za odlučivanje o sukobu interesa)
- Website of the President of the Republic of Croatia
- Website of the Government of the Republic of Croatia
- Open Data Portal of the Republic of Croatia
- Website of the Croatian Parliament (Hrvatski sabor)
- Website of the Supreme Court of the Republic of Croatia
- Website of the Constitutional Court of the Republic of Croatia
- Website of the Court Organization of the Republic of Croatia
- Website of the State Audit Office of the Republic of Croatia
- Website of the Croatian National Bank
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