Defining political exposure in Brazil

In Brazil, the definition of a politically-exposed person can be confusing. See below for further detail on what positions/functions and familial relationships constitute political exposure.

What counts as an important public job or function?

  • In Brazil

    • Holders of elective office in the executive and legislative branches of the federal government

    • Members of the Administrative Office of Brazilian Courts, the Federal Supreme Court and higher-level courts, federal regional courts, labor and electoral regional courts, the Superior Council of Labor Justice, and the Federal Justice Council

    • Members of the National Council of Public Prosecutors and Defenders, the Chief Federal Prosecutor, the Assistant Chief Federal Prosecutor, the Chief Prosecutor for Labor Matters, the Chief Prosecutor of Military Justice, the Deputy Chief Federal Prosecutors, and the Chief Prosecutors for the Supreme Courts of the States and the Federal District

    • Members of the Brazilian General Accounting Office, the Chief Prosecutor and the Assistant Chief Federal Prosecutor of the Office of Public Prosecutors and Defenders for the Brazilian General Accounting Office

    • The presidents and national treasurer of political parties

    • The governors and secretaries of States and the Federal District, deputies of States and of the Federal District, and presidents, or the equivalent thereto, of entities of indirect public administration of the States and the Federal District, and the chief justices of state supreme courts, military tribunals, presidents of General Accounting Offices, or the equivalent, of the States and the Federal District

    • Mayors, city council members, secretaries of city governments, presidents or the equivalent of entities of indirect municipal administration and the presidents of General Accounting Offices or equivalent entities of municipalities.

  • Abroad

    • Heads of state or governments

    • Holders of high-ranking government positions

    • General officials and high-ranking members of the judiciary branch

    • High-ranking executives of government-owned corporations

    • Political party officials

    • High-ranking officials of international public- or private-law entities 

Who counts as a closely related person?

  • Family Members

    • Lineal or collateral relatives up to the second degree, including spouses, domestic partners, and stepchildren

  • Close Associates

    • Persons who hold joint interest in a private-law legal entity or unincorporated arrangements

    • Persons standing as an agent, even if under a private instrument

    • Natural persons who control legal entities or unincorporated arrangements known for having been created for the benefit of a politically exposed person.

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