bank asks if my company has contracts with the government

PEP status and government contracts are two different questions

This question usually does not stand alone, but in the series around the client due diligence that the bank is required to conduct under the Anti-Money Laundering and Counter-Terrorist Financing Act (Wwft). The bank tries to assess the relationship risk in this way: government contracts are not a problem in themselves, but they can, together with other signals — such as a politically exposed person in management — lead to a higher risk classification. Note the distinction from the question of whether a director or stakeholder is a politically exposed person: that is a status of a person, whereas government contracts are a characteristic of the enterprise. Banks sometimes ask both, in the same breath, but they are separate answers.

If your company has contracts with the government, that is usually simply to be confirmed: it is a matter of fact, not an assessment. If you have no contract with any government body, then "no" is the answer — that too is a fact and not a risk in itself. If you are unsure whether an assignment counts (think of a municipality, a public body, or a European institution), it is more accurate to look at the contracting party on the agreement itself than to guess. This subject differs in that respect from the question about the source of the company's assets: there you are asked for a narrative, here for a simple yes or no, possibly with a contract name added.

Basis: client due diligence under the Wwft

The bank's obligation to ask these kinds of questions stems from client due diligence under the Wwft: the bank must assess relationship risks and collect data for this purpose, including relations with government bodies. There is no separate legal provision that requires your enterprise itself to report this — the reporting obligation rests with the bank, not with you. What we can provide from the supply chain file is limited to what is actually recorded there: if there is a contract with a government body registered, we confirm that; if that is not recorded, we leave the answer open rather than assume a "no".