Understanding PEP matches

Finding that a client is a Politically Exposed Person (PEP) does not mean you cannot do business with them. It means you must apply Enhanced Customer Due Diligence (ECDD).

What constitutes a PEP?

A PEP is an individual who is or has been entrusted with a prominent public function. This includes heads of state, senior politicians, senior government officials, judicial or military officials, senior executives of state-owned corporations, and important political party officials.

Steps to take:

• Obtain Senior Management Approval: Before establishing or continuing a business relationship with a PEP, ensure you have approval from senior management.
• Establish Source of Wealth: Take reasonable measures to establish the source of wealth and source of funds of customers and beneficial owners identified as PEPs.
• Enhanced Ongoing Monitoring: Conduct enhanced ongoing monitoring on that relationship.