The term ‘politically exposed persons’ (PEPs) refers to people who hold high public office. The current Money Laundering Regulations require firms to apply extra measures, called “enhanced due diligence” when dealing with those who are PEPs in a state other than the UK, as well as family members or close associates of those PEPs.
The anti-money laundering regime is being updated by 26 June this year and this will include expanding the definition of a PEP to include those holding a politically exposed position in the UK.
This means that more firms will have PEPs.
We do not intend to repeat the guidance here as the paper is relatively brief and well presented. It provides useful instruction, for example how to differentiate between a higher and lower risk PEP, and who is classified as a family member or a close associate.
It is essential reading though, if only to clarify whether or not your firm has PEPs.
You can find the consultation here.
FCS Transitional Arrangements
Steve Bailey Compliance Update
As you will be aware the Financial Services Authority ceased to be and the Financial Conduct Authority took over the regulation of financial advice firms on 01 April 2013.
The FSA issued PS13/05 last week which includes updated rules and transition arrangements. The policy statement itself is 88 pages but the ‘appendix (3)’ that accompanies it is a mere 1990 pages so you must excuse us for not as yet absorbing every word. The document can be seen here.