Norway fixes PEP list: obliged entities must apply it by 1 January 2027

Norway has fixed by regulation which Norwegian positions and functions confer status as a politically exposed person (PEP) under the anti-money-laundering rulesRevisorforeningen. Reporting entities under the Money Laundering Act (hvitvaskingsloven) — including auditors, banks, financial institutions, lawyers and other obliged entities — must use the new PEP list as the basis for compliance no later than 1 January 2027Revisorforeningen. A person holding a Norwegian position that no longer counts as PEP, but was previously treated as such, may immediately be treated as no longer being PEPRevisorforeningen. Reporting entities may equally rely on corresponding PEP-position lists prepared by other EEA states.

PEPs are persons holding central public offices or functions considered to carry heightened risk of corruption or misuse of influence. Reporting entities must apply enhanced customer due diligence (forsterkede kundetiltak) to themRevisorforeningen: approval from a superior before establishing or maintaining the customer relationship, plus adequate steps to establish the origin of wealth and funds. The measures continue for at least one year after the PEP leaves the officeLovdata, and apply equally to close family members and known close associates of a PEP.

At the top of the state the list covers the King, the Prime Minister, cabinet ministers, state secretaries, members of the Storting, deputies meeting permanently for more than 12 months, and members of the central board or equivalent governing body of political parties represented in the Storting. In the courts: Supreme Court judges, Labour Court judges and Norwegian judges at international courts. In the foreign service: Norwegian ambassadors and charges d'affaires at Norwegian embassies, but not consuls.

In the government apparatus and Armed Forces: the Regjeringsraad, permanent secretaries (departementsraader), the Chief of Defence, lieutenant generals and vice admirals. Oversight and the central bank: the members of the Riksrevisjon collegium, the Auditor General and the members of the main board of Norges Bank.

The listed tax, supervisory and law-enforcement heads are the Tax Director, the Customs Director, the director and board members of Finanstilsynet, the Director of Public Prosecutions, the National Police Commissioner, the chief of the Special Unit for Police Affairs, the head of the Criminal Cases Review Commission, the director of the Civil Affairs Authority, the PST chief, and the directors and board members of Advokattilsynet and the Courts Administration.

Security, preparedness and immigration administration: the directors of DSB, NSM, SKM, the Correctional Service directorate, UDI and the Lotteries and Foundations Authority, plus the Governor of Svalbard. Sector management: the CEO and board members of Eksportfinansiering Norge, the head of Norges Bank Investment Management, and the directors of the Fisheries Directorate, the Competition Authority, the Maritime Authority, Forsvarsmateriell, Husbanken, Nkom, Statsbygg, NVE, RME, the Consumer Authority, the Havindustritilsynet, the Railway Directorate, the Coastal Administration, the Civil Aviation Authority, the Public Roads Administration, DEKSA and the Environment Agency.

Health, agriculture and welfare: the directors of the Health Directorate, the Institute of Public Health, the Directorate for Medical Products, DSA, NAV and the Labour Inspection Authority, plus the CEOs of Mattilsynet and the Agriculture Directorate. Development cooperation: the Norad director, the head of IOM Norge and the director of the UNDP centre for good governance. In six state enterprises — Bane NOR SF, Enova SF, Gassnova SF, Innovasjon Norge, Norsk helsenett SF and Statnett SF — the managing director and board members are PEPs.

A person temporarily holding a PEP position through appointment, substitution or similar counts as a PEP only if the function lasts at least 12 monthsRevisorforeningen.

Legal basis: the new PEP regulation (forskrift) under the Money Laundering Act (hvitvaskingsloven), whose sections 17–18 require enhanced customer due diligence for PEPs.