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.
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Conduct Rules Breaches – follow up
Huw Reynolds Compliance Conduct, FCA, Pension, Senior Manager, Update
We wrote recently about the Conduct Rules and, in particular, breaches and notifications . See here. This article is intended to clarify some of the grey around COCON breaches. All of the following is taken from Policy Statement PS 18-14. When is disciplinary action required? When and how a firm decides to undertake disciplinary action […]