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.



Regulatory permission – use it or lose it
Michael Senior Compliance 2021, FCA, ML, protection, Register
The FCA has published draft guidance on a new power that allows it to move faster to remove regulatory permissions that are no longer being used by financial services firms. Responses to the consultation (CP21/28) close on 29 October 2021. The driver behind the proposed power is the regulator’s belief that incorrect or outdated permissions […]