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.
Ukraine – 10% drop reporting
Alistair MacDougall Compliance 2020, 2022, COVID-19, FCA, Update
The current hostilities in Ukraine have caused significant market drops and may continue to do so. Accordingly, a reminder about the 10% drop reporting requirements is timely. Readers will recall the early days of the Covid pandemic in 2020 caused a period of market volatility that necessitated issue of 10% drop notifications to clients. […]