At what level / grade / designation officers should be considered as PEP?

Regulated person shall implement appropriate internal risk management systems, policies, procedures and controls to determine if any customer or a beneficial owner is a PEP. However, the regulated person should consider the nature of the prominent public function held by the PEP (e.g. level of seniority, access to or control of public funds and the nature of the position).
Regulated persons may develop a questionnaire with specific reference to criteria that identify PEPs including family members and persons known to be close associates of the PEP. Such a questionnaire may be made part of account opening form.