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Politically Exposed Person (PEP)
ImageWhile there is no set definition for a PEP, the Financial Action Task Force (FATF) has issued guidelines defining the term. It has also been addressed by USA Patriot Act and the European Union Directive, and generally encompasses the following:

 

  • current or former senior official in the executive, legislative, administrative, military, or judicial branch of a foreign government (elected or not)
  • a senior official of a major foreign political party
  • a senior executive of a foreign government owned commercial enterprise, being a corporation, business or other entity formed by or for the benefit of any such individual
  • an immediate family member of such individual; meaning spouse, parents, siblings, children, and spouse's parents or siblings
  • any individual publicly known (or actually known by the relevant financial institution) to be a close personal or professional associate

 

The nature and extent of due diligence conducted on PEPs may vary according to the presence of potential risk factors.  More extensive due diligence, for example, may be appropriate for new clients; clients who operate in, or whose funds are transmitted from or through, jurisdictions with weak AML controls; and clients whose lines of business are largely cash-based, such as casinos. The level of due diligence should also reflect the size and frequency of account transactions.

 

In the United Kingdom, the Joint Money Laundering Steering Group (JMLSG) has devoted considerable attention to PEPs, reflected in the revised JMLSG Guidance

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