By N. Carnot, V. Koen, B. Tissot
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If such an approach is taken, a set list of PEPs would also make PEP checks easy to circumvent by launderers. Where banks rely on such lists, they must be aware of their limitations (for example, inaccuracies, lack of updates) and should not rely upon the list as the only means of checking PEP status. Other CDD checks must also be conducted. Identification of the Beneficial Owner: Will the True Owner Please Stand Up? One of the difficulties emphasized in the context of PEP identification is determining the beneficial owner, the natural person(s) who ultimately own or control a customer or transactions, beneficiaries, controllers, or relevant third parties.
It is, therefore, important that a PEP definition include close associates and family members in addition to the prominent public official. Of course, this raises the issue of how to define these two categories. Unfortunately, family and close associates are defined differently among the standard setters. 43 Regarding family members, UNCAC and FATF do not limit the degree of relationship, while the Third EU Directive focuses on immediate family members, which may not be sufficient in cultures and jurisdictions in which the extended family maintains very close ties.
47 Recommendation: Law or regulation should include a requirement to determine whether a beneficial owner is a PEP in accordance with the Methodology for FATF Recommendation 6. 47. ” 33 Politically Exposed Persons: Preventive Measures for the Banking Sector When to Check? Banks should, of course, check whether a potential customer, existing customer, or beneficial owner, is a PEP. In the private banking institutions visited, this check was often made before the establishment of a business relationship; the account could not be opened until all relevant investigations, such as beneficial ownership and the PEP’s identification, had been undertaken.