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Politically Exposed Persons (PEPs)

A Politically Exposed Person (PEP) is an individual who is or has been entrusted with a prominent function and as such could potentially abuse such a position or function for the purposes of laundering or other predicate offences, such as corruption or bribery.  Due to the high risks associated with PEPs, The Financial Action Task Force (FATF) recommends that additional AML and due diligence controls and measures are put into place when entering into a business relationship with a PEP.

The company utilises existing commercial resources and other databases for the identification of PEPs and always ensures that initial due diligence KYC checks include reviewing individual names against these resources and databases to identify PEPs immediately. We also keep our own in-house list of PEPs with which to cross-check KYC data.

The company invokes additional due diligence measures for all identified Politically Exposed Persons (PEPs) and where such a proposal to establish a business relationship or carry out a one-off transaction with a PEP exists, we always ensure that: –

  • Director or Senior Management approval for establishing the business relationship is obtained and recorded
  • We take reasonable measures to establish the source of wealth and source of funds
  • We conduct enhanced ongoing monitoring of the business relationship

10.1.4 Cross-Border Due Diligence

Where the course of business supply and provision includes any cross-border transactions and/or relationships, the company ensures that in addition to performing normal due diligence measures, we also: –

  • Gather sufficient information about the individual or legal entity to fully understand the nature of their business and requirements and using publicly available information, determine the reputation of the person or institution and the quality of supervision, including whether it/they have been subject to a money laundering or terrorist financing investigation or regulatory action
  • Where the relationship applies to an organisation (legal entity), we also:
    • Document the respective responsibilities of each institution in the form of an agreement, SLA and/or contract
    • Assess the organisations anti-money laundering and terrorist financing controls and any due diligence procedures
    • Obtain approval from Directors or Senior Management before establishing new correspondent

10.1.5 Non-UK Country AML Requirements

NOTE: For country requirements, other than the UK, PWC offer an exceptional guide as to the requirements, obligations and standards for each county. The guide can be found here and can be used to replace the above content to suit your country/business requirements.