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.
Pension transfer advice – assessing transfer risk
Alistair MacDougall Compliance 2015, 2018, 2019, 2021, DBAAT, Drawdown, FCA, Pension, Pension Transfer, PI, transfer
It has been well publicised that the FCA has aimed increasingly close scrutiny in the direction of firms that have been providing advice in relation to defined benefit pension transfers. Apparently caught off guard by the then Chancellor’s introduction in the Pension Schemes Act 2015 of what are generally called ‘pension freedoms’, the regulator has […]