High Risk Customers - PEPs
- 02:33
The assessment and management of politically exposed persons (PEPs) as high-risk clients for money laundering risks.
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Financial institutions that have clients who are politically exposed persons or PEPs run the risk that the client's money is dirty because it was corruptly made through the use of their political influence. To mitigate this risk, wholesale financial institutions have to identify which of their client entities are owned or controlled by PEPs or close associates of PEPs. When an institution identifies that a prospective client is a PEP or controlled by a PEP, it does not automatically have a reason to deny service. Instead, the financial institution is obligated to carry out what is called enhanced due diligence or EDD to obtain assurance that the client's wealth was legitimately earned. EDD involves a deeper dive into the client's background, sources of wealth and ownership than would usually be required. It takes more time and is more costly than standard customer due diligence. Sometimes EDD will confirm the worst fears about a PEP's source of wealth and business interests, in which case the firm has every reason to deny service. Identifying PEPs can get quite complicated. For instance, are PEPs politically exposed forever? What about PEPs who no longer hold high office? The key question is whether the PEP still has sufficient influence to fill their pockets corruptly, for example, Hillary Clinton still has broad influence despite not having been directly involved in politics since 2016. So the answer is emphatically yes, she would still be classified as a PEP. However, there are thousands of lower ranking former public servants who would not be classified as PEP's. If the firm is satisfied, they no longer have any influence. The obligation for making this decision sits with the firm, looking at things from a different perspective. Should celebrities be treated as PEPs too? Ordinarily no. But there are many examples of celebrities who've moved into positions holding political influence. For example, let's consider Angelina Jolie, she's not just a famous actress until 2022 she was a special envoy to the UN High Commission for refugees. She's therefore potentially a PEP. The key question for a financial institution to ask is how much and what type of influence do potential PEPs have?