what if a family member of the director is a politically exposed person

Family members of directors are also covered by the PEP question

Yes: the PEP question does not only concern the director or UBO themselves, but also their family members and close associates. This is not an invention of the client sending out the list — it follows directly from the client due diligence that institutions must perform under the Act on the Prevention of Money Laundering and the Financing of Terrorism (Wwft). A bank or other Wwft institution that identifies a politically exposed person (PEP) as a customer or UBO must also check whether family members — such as spouse, children, parents — present an increased risk. This is why that question also comes to your business, even if the director themselves has never held a political office.

If the chain file marks this question as "to be determined", this usually means there is no confirmed source that rules it out or confirms it. PEP status of a family member is not data that appears in the Business Register or an annual report — it is something the business must investigate and assess itself. Without a separate declaration or confirmation, the system cannot enter a "yes" or "no" here. This topic is often related to the question of whether a director or stakeholder is themselves a politically exposed person: whoever has already investigated that question for the director also needs the overview to answer the question about family members.

Where the family extension in the Wwft comes from

The obligation to assess family members and close associates of a PEP also follows from the definitional provisions and enhanced customer due diligence in the Act on the Prevention of Money Laundering and the Financing of Terrorism. Institutions that must apply this law — banks, insurers, and other Wwft-obligated parties — are required to also investigate the wider circle around that person when a PEP signal is detected. Whoever must determine this for their own business often first finds out who the beneficial owners of the company are, since the PEP test is usually carried out separately for each UBO and for each director.