Senior Military Officers as PEPs
Short answer: yes. Senior officers of the armed forces are politically exposed persons. The 2021 regulation (Dz.U. 2021 poz. 1381) lists officers who hold a service position classified to general or admiral ranks (item 22), together with the Minister of National Defence’s authorised representative appointed by a separate decision (item 23).
The interpretation was confirmed by the Ministry of National Defence, which indicated that “senior officers” means officers whose posts are graded to general or admiral ranks.
Which positions are covered
Because the test is the rank grading of the post rather than a fixed list of titles, the scope includes the top command and staff positions, among them:
- Chief of the General Staff of the Polish Armed Forces
- General Commander and Operational Commander of the Armed Forces
- Commander of the Special Forces Component
- Commander of the Warsaw Garrison and Commandant of the Military Gendarmerie
- Commander of the Territorial Defence Forces
- heads of the Armed Forces Support Inspectorate
- deputy chiefs of the General Staff and their equivalents
- division and brigade commanders and their deputies, and division and brigade chiefs of staff
- inspectors of the land forces, air force, navy and branches of service
- directors and deputy directors of departments, and military attachés
- commanders and deputy commanders of the land, air and maritime operations centres
The common thread is a position graded to a general or admiral rank.
Why senior officers are PEPs
Senior military officers can control significant public resources and procurement, which is why the AML framework treats them as politically exposed. Institutions must apply enhanced due diligence to them, their family members and close associates.
Screening in practice
Military titles, ranks and post names vary and are often translated inconsistently, which makes name matching harder than for civilian roles. A screening service that carries structured data on senior officer positions reduces both misses and false positives. Hyperflow provides PEP screening through an API so these checks run automatically.
UK perspective
In the UK, PEP status under the Money Laundering Regulations 2017 likewise extends to senior military officers, reflecting the same risk rationale that applies in Poland.