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Dealing with politically exposed persons: Navigating the changing regulatory environment

Susannah Cogman and Elizabeth Head

Journal of Financial Compliance, 2017, vol. 1, issue 2, 102-111

Abstract: The increased risk posed by dealings with politically exposed persons (PEPs) will already be well known to regulated firms. Although regulators have been keen to emphasise the need to manage this risk, clear and detailed guidance on exactly how firms must do so has been harder to come by. New regulatory requirements will bring the practical challenges involved in dealing with PEPs into sharper focus. This paper provides an overview of the current PEPs regime and highlights forthcoming changes at both the EU and UK level. We examine, in particular, the proposed changes to the UK PEP regime, aimed at promoting a risk-based approach to this category of customers. We also provide an overview of the practical compliance steps that firms should consider taking in relation to PEPs in order to ensure that they are meeting regulatory expectations.

Keywords: politically exposed persons; PEP; AML; 4MLD; 5MLD; Criminal Finances Bill; Bank of England and Financial Services Act 2016 (search for similar items in EconPapers)
JEL-codes: E5 G2 K2 (search for similar items in EconPapers)
Date: 2017
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