Is a Mayor, Burmistrz or City President a PEP?
Short answer: yes. Since 31 October 2021 the Polish list of politically exposed positions explicitly includes wójt, burmistrz and prezydent miasta, together with their deputies and starosta. The list is set out in the Regulation of the Minister of Finance, Funds and Regional Policy of 27 July 2021 (Dz.U. 2021 poz. 1381), issued under the AML Act of 1 March 2018.
This is a good example of why PEP screening cannot rely on old interpretations. Before the 2021 regulation, the AML Act listed PEP categories in general terms and the treatment of local government was genuinely disputed. Once the regulation named the positions directly, that debate ended.
What the regulation says
The regulation lists national positions that are politically exposed. The local government entries are unambiguous:
- wójt, burmistrz, prezydent miasta (item 42)
- deputy wójt, burmistrz and prezydent miasta (item 43)
- starosta (item 44)
- other members of the powiat board, other than the starosta (item 45)
- wojewoda and wicewojewoda (items 38 and 39)
- marszałek województwa and other members of the voivodeship board (items 40 and 41)
In other words, the elected heads of gminas and cities, the heads of powiat administration, and the regional government level are all in scope.
Why the old “no” answers were wrong
The earlier position, still visible in some 2019 material, argued that wójt, burmistrz, prezydent miasta and starosta were not literally named in the AML Act, and therefore fell outside the definition. That reading ignored the fact that the Act delegated the detailed list to a ministerial regulation. When the regulation arrived in 2021, it named these positions directly.
For a regulated institution, the practical consequence is simple: local government officials must be screened and, where a match is found, treated as PEPs requiring enhanced due diligence.
What enhanced due diligence means here
For a customer who is a wójt, burmistrz, prezydent miasta or starosta, the institution must:
- establish the source of funds and source of wealth
- obtain senior management approval to establish or continue the relationship
- apply enhanced ongoing monitoring
The same applies to their family members and close associates.
Screening in practice
The list is long and changes as positions are created or renamed, which is why manual checking is error prone. A screening tool that carries the current Polish PEP list and updates it automatically removes the guesswork. Hyperflow exposes PEP screening through a simple API, so a name check can run as part of onboarding or periodically.
UK perspective
In the United Kingdom, PEP status is defined under the Money Laundering Regulations 2017 and supervised by the FCA. The UK regime covers foreign and domestic PEPs alike, with enhanced due diligence required for the person, their family members and known close associates.