Identifying Politically Exposed Persons (PEPs) and managing the associated risks is a crucial element of Anti-Money Laundering (AML) and Countering the Financing of Terrorism (CFT) strategies. Asset disclosure for political officials, aimed at fostering transparency, preventing corruption, and reducing the risk of power abuse, has become a major tool for national policymakers and supervisory bodies. However, institutional, cultural, and technical complexities pose significant challenges to the effective implementation of asset disclosure and PEP identification.
This article, using an analytical-comparative method, expands on the theoretical foundations of political risk, critiques international practical experiences (such as those of Estonia and Georgia), and analyzes domestic and international regulations. It demonstrates that the effectiveness of an asset disclosure system hinges on the simultaneous realization of three fundamental pillars: (1) establishing an integrated system connected to financial institutions for active monitoring, (2) designing independent and technical mechanisms for verifying declared assets, and (3) strengthening robust enforcement measures alongside institutional culture-building.
The findings indicate that in the absence of any of these pillars, the asset disclosure system becomes a formalistic and ineffective tool, and merely imitative solutions will prove inadequate. Consequently, this research proposes the native strategy of "Integrated Smart Monitoring." This strategy involves enhancing data infrastructure, mandating digital verification, and establishing progressive enforcement mechanisms, all designed in consideration of Iran's legal and cultural requirements. Comparative experience confirms that genuine transparency and effective PEP risk management can only be achieved through such a comprehensive and coordinated approach.