UK Politically Exposed Persons (PEPs) Alignment with FCA Guidance FG 25/3

Last updated: April 7, 2026

 

The Financial Conduct Authority (FCA) has unveiled its Finalised Guidance, FG 25/3, on "The treatment of politically exposed persons for anti-money laundering purposes." Published on July 7, 2025, this document serves as a crucial update for firms navigating the complexities of anti-money laundering (AML) regulations concerning Politically Exposed Persons (PEPs).

The significance of this document lies in its pragmatic approach. It aims to assist firms in adopting a proportionate strategy when dealing with PEPs. This update stems from a review of the FCA's previous guidance (FG17/6), a review mandated by the FMSA 2023. The FCA found that while the existing guidance remained largely appropriate, certain amendments were necessary to align with changes in the UK's legislative framework.

 

In line with the updated Guideline, ComplyAdvantage is implementing two key enhancements to our UK dataset to ensure continued alignment with regulatory requirements and to further improve data granularity, as outlined below:

1. Alignment with the latest FCA Guidance (FG 25/3): To provide clear direction for client screening and exclude roles not subject to FCA requirements, we are making the following adjustments:

  • Removal of non-executive board members (NEBMs): NEBMs of UK civil service departments are no longer classified as PEPs. We will stop collecting these roles, and existing records will be delisted with a removal date referencing the FCA exclusion.

  • Refined scope for political parties: In alignment with the guidance, we are narrowing our coverage of political party governing bodies.We will now exclude members of governing bodies for regional or local political parties that do not have representation in a national or supranational Parliament (or similar legislative body).

  • Clarification notes for roles outside the FCA’s PEP screening requirements: Our clients outside the UK may want to continue receiving information about roles the FCA has indicated fall outside PEP screening requirements; therefore, we will retain profiles for roles such as regional judges or political party members. To assist with your risk assessment, these entities will now include a note on their profile indicating that the role has been identified by the FCA as typically falling outside the scope of PEP screening requirements in the UK.

2. UK PEPs Increased Granularity Update: In addition to the regulatory alignment, we are making data quality improvements to UK PEP profiles to provide richer context on their role and responsibility.

  • We are updating approximately 2,000 entities with more precise institution-type and political position information. This ensures your screenings are supported by more granular, up-to-date information on government structures, with politically exposed persons distinctly listed under institution types such as State Security, National Public Agency, Agency under Ministry, or Court of Accounts.