The Money Laundering Regulations 2017 impose on the Firm a requirement to identify clients that are “politically exposed persons” (PEPs) or have been PEPs in the last 12 months or clients that are either a family member or a known close associate of a PEP.
A PEP is defined as “an individual who is entrusted with prominent public functions, other than a middle-ranking or more junior official”. Examples would include:
- Heads of State, Heads of Government, Ministers and Deputy of Assistant Ministers;
- MP’s;
- Members of Governing Bodies of political parties;
- Members of the Supreme Court, constitutional courts or any judicial body whose decisions are not generally subject to appeal;
- Members of courts of auditors or boards of central banks;
- Ambassadors, Charges d’affaires and high-ranking officers in the armed forces;
- Members of the administrative, management or supervisory bodies of State-owned enterprises;
- Directors, deputy-directors and members of the board or equivalent function of an international organisation.
PEPs can also include:
- Any politically exposed person’s family members.
- Close business associates who could be viewed as politically exposed persons.
- The beneficial owner of the person’s property (someone who enjoys the benefits of ownership even though the title of the property is in another person’s name) who may be viewed as a politically exposed person.
If you are or think you may fall into one or more of the above categories or have done so in the last 12 months or if you are the spouse, partner, child or spouse/partner of a child or the parents of a person who currently falls into one or more of the above categories, please confirm by providing details at the end of this Form of Authority.
If you have joint beneficial ownership of a legal entity, legal arrangement or other close business relationship with a PEP or sole beneficial ownership of a legal entity or legal arrangement which was set up for the benefit of a PEP, you may fall within the definition of a “known close associate” and, therefore, should confirm by providing details above.
If you are unsure whether any of the above applies to you, please complete the section with the relevant details to enable us to investigate further. Please do telephone if you are at all unclear how to proceed.
