There are many misconceptions about Politically Exposed
Persons (PEPs).
Many people think that it is not allowed to service PEPs. Many
people think that only Heads of State and Government Ministers are
PEPs. Many people fail to realise or understand the ML/FT risks
posed by PEPs. Many people think that all
PEPs pose the same risk.
This article aims to address these misconceptions and will at
the same time provide guidance to those practitioners who deal with
PEPs or would like to service PEPs in the future.
Who can be classified as a PEP?
A PEP is a natural person who is or has been
entrusted with a prominent public function, other than
middle-ranking or more junior officials. Part I of the FIAU's
Implementing Procedures provides a non-exhaustive list of public
functions that the holder thereof would be classified as a PEP.
These include positions ranging from Heads of State, Ministers,
members of Parliament, ambassadors, charge d'affaires, members
of the
