November 10, 2026 · Jurisdiction Briefing · 7 min read

Mauritius: politically exposed persons under FIAML Regulation 15 and the Bank of Mauritius Guideline, and where the Guideline asks for more

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Regulation 15 of the Financial Intelligence and Anti-Money Laundering Regulations 2018 (FIAML Regulations) sets the rules for politically exposed persons (PEPs). The Bank of Mauritius AML/CFT Guideline restates them at paragraphs 6.156 to 6.160 and then adds its own expectations up to paragraph 6.170, with a list of PEPs in the Annex to Chapter 6. This briefing sets the two side by side, and flags one point where the Guideline’s restatement is narrower than the regulation.

Which texts these are, and whether they are current

The Regulations. We use the consolidated FIAML Regulations 2018 the FIU uploaded on 3 August 2022. A search of the FIU’s media library on 9 November 2026 returned no later copy. That does not rule out a later government notice, so check the Gazette before relying on the regulation text.
The Guideline. The Bank’s Guideline on Anti-Money Laundering and Combating the Financing of Terrorism and Proliferation is dated January 2020 and is listed under 15 January 2020. The newer entries on the Bank’s guideline listing, read on 9 November 2026, are on other topics.
How binding the Guideline is. Under paragraph 2.13, where the Guideline uses “shall”, “must” or “should”, “it is a mandatory requirement”. Several PEP paragraphs below say “should”.

The Guideline applies to its own “financial institutions”: banks, non-bank deposit taking institutions, cash dealers and money lenders licensed by the Bank under the Banking Act 2004, and licensees under the National Payment Systems Act 2018. The regulation applies to every reporting person.

Who counts as a PEP

The regulations define a PEP as a foreign PEP, a domestic PEP or an international organisation PEP. The Guideline repeats the definition at 6.156.

Domestic PEP: a natural person who “is or has been entrusted domestically with prominent public functions in Mauritius”. The definition names the Head of State and of government, senior politicians, senior government, judicial or military officials, senior executives of state owned corporations and important political party officials.
Foreign PEP: the same categories, for prominent public functions entrusted by a foreign country.
International organisation PEP: a person entrusted with a prominent function by an international organisation, including directors, deputy directors and members of the board or equivalent functions.

Each limb also covers any other person or category a supervisory authority or regulatory body specifies after consultation with the National Committee.

The Guideline’s Annex turns this into a list. It names 15 domestic categories, among them all members of the National Assembly and the Speaker, members of the Rodrigues Regional Assembly, the Governor and Deputy Governors of the central bank, chairmen and chief executive officers of parastatal organisations, independent bodies and state-owned enterprises, commissioners of various government bodies, advisers to heads of state and ministers, mayors and presidents of district councils, and the head of the national secret services. It names eight foreign categories, from heads of state and ministers to members of the boards of central banks and directors of international organisations.

What regulation 15 requires

Who	What the regulation requires, on top of normal CDD	Guideline
Foreign PEP, as customer or beneficial owner	Risk management systems to determine whether the customer or beneficial owner is a PEP; senior management approval before establishing, or continuing for existing customers, the relationship; reasonable measures to establish source of wealth and source of funds; enhanced ongoing monitoring (reg 15(1))	Restated at 6.158
Domestic PEP or international organisation PEP	Reasonable measures to determine whether the customer or beneficial owner is such a person; where the relationship is higher risk, the measures in 15(1)(b) to (d) (reg 15(2))	Restated at 6.159, but see below
Family members and close associates	The relevant requirements of 15(1) and (2) apply to family members or close associates “of all types of PEP” (reg 15(3))	6.160, “as set out in the Annex”

Regulation 12(1)(e) also lists, “subject to regulation 15”, the case where the customer or applicant for business is a politically exposed person among the situations that call for enhanced CDD.

Regulation 15(4) adds a rule for life insurance policies: before payout, reasonable measures to determine whether the beneficiaries, or the beneficial owner of the beneficiary, are PEPs, with further steps where higher risks are identified. It is not part of a bank’s ordinary book, and we leave it aside here.

Where the texts do not line up

International organisation PEPs at higher risk

Regulation 15(2)(b) applies the measures in 15(1)(b) to (d) “when there is higher risk business relationship with a domestic PEP or an international organization PEP”. Paragraph 6.159(b) of the Guideline mentions only a domestic PEP. Yet paragraph 6.161 of the same Guideline says the measures applicable to a PEP are also applicable to persons entrusted with a prominent function by an international organisation.

Our reading: the regulation is the higher text. Apply the 15(1)(b) to (d) measures to a higher-risk international organisation PEP, whatever 6.159 omits.

Former PEPs

The definitions cover a person who “is or has been” entrusted with the function, and regulation 15 sets no end date. Paragraph 6.170 of the Guideline deals with a PEP no longer in a prominent function: for at least 12 months, take into account the continuing risk posed by that person and apply appropriate and risk sensitive measures until the person is deemed to pose no further PEP-specific risk. The reasons for declassifying should be documented and made available to the Bank on request. Paragraph 6.165 adds that declassifying a low-risk relationship needs careful consideration of continuing money laundering risks and approval by senior management.

Our reading: 12 months is a floor, not a release date. Declassification is a documented, senior-approved decision, not an automatic step in a screening tool.

What the Guideline adds

Family members, named. Paragraph 6.162 lists spouses, a partner treated by national law as equivalent to a spouse, children and their spouses or equivalent partners, and the parents of a PEP. The regulation defines family members by relation through consanguinity, marriage or similar civil partnership, without a list.
Close associates, named. Paragraph 6.162 includes people known to have joint beneficial ownership of legal entities or legal arrangements, or any other close business relations, with a PEP, and people with sole beneficial ownership of an entity or arrangement known to have been set up for the de facto benefit of a PEP.
Entities of local PEPs. Under paragraph 6.161, entities relating to local PEPs “would comprise entities that are 20 per cent or more owned or controlled by those local PEPs”.
How to find them. Paragraph 6.165 expects institutions to gather sufficient information from a new customer, including on the beneficial owner, and to check publicly available information or access commercial electronic databases. Paragraph 6.166 mentions requiring a declaration of beneficial ownership at the outset.
Country exposure. Paragraph 6.167 asks institutions to assess which countries they deal with are most vulnerable to corruption, and names the Transparency International Corruption Perceptions Index as one source. Where they do business in such countries, 6.168 asks them to establish who the senior political figures are and whether customers have connections to them, noting that connections may be acquired after onboarding.
Detailed due diligence. Paragraph 6.169 lists close scrutiny of complex structures; every effort to establish source of wealth, including the economic activity that created it, and source of funds, at the outset and on an ongoing basis; a profile of expected activity, regularly reviewed; approval at senior management or board level to start the relationship, and to continue it where an existing customer is found to be or becomes a PEP; review by senior management, “at least yearly”, documented; and close scrutiny of unusual features such as very large transactions, demands for secrecy, cash or bearer instruments, and regular sums just below a typical reporting amount.

What breach can cost

The Regulations. Regulation 33, in the FIU’s copy, makes contravening the regulations an offence: on conviction, a fine not exceeding one million rupees and imprisonment for a term not exceeding 5 years.
The Guideline. The Bank says failure to meet it will be dealt with under its Sanctions Framework, which may mean non-monetary sanctions, monetary penalties and, in very serious instances, revocation of the licence.

Context: how Mauritius is rated

On its AML/CFT page, the Bank of Mauritius shows FATF Recommendation 12, politically exposed persons, as Compliant in the consolidated technical compliance ratings following the ESAAMLG re-ratings. The page says the FIAML Regulations 2018 were made to address FATF requirements including those on politically exposed persons.

What this means for an MLRO

Our view: the regulation is short, and most of the work sits in the Guideline. The points most likely to be missed are the ones the regulation states and the Guideline blurs (higher-risk international organisation PEPs), and the ones the Guideline adds that a screening list alone will not catch: family members by name, 20 per cent entities, and connections that arise after onboarding.

Six things worth doing

Map your PEP categories to the Annex. Check that your screening and self-declaration cover all 15 domestic and eight foreign categories, including Rodrigues Regional Assembly members, mayors and heads of parastatal bodies.
Fix the international organisation gap. Make sure your procedure applies senior approval, source of wealth and funds, and enhanced monitoring to a higher-risk international organisation PEP, as regulation 15(2)(b) requires.
Extend to family and associates. Capture spouses, children and their spouses, and parents, and the joint and sole beneficial ownership links in 6.162.
Flag the 20 per cent entities. Link corporate customers to local PEPs who own or control 20 per cent or more.
Diarise the yearly review. Record a documented senior management review of each PEP relationship at least once a year.
Control declassification. Require a written rationale, senior management approval and the 12-month minimum before a former PEP is declassified, and keep the file ready for the Bank.

SonarPulse in this jurisdiction: AML/CFT screening software for Mauritius

Sources

This article draws on the following sources. Follow the links for the original text.

For information only. This briefing is not legal advice: check the cited sources and take advice on your own position.

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