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ARTICLE · 15 FEBRUARY 2018

Who Is John Smith?

Business relationships with family members and known close associates of a PEP are also subject to greater scrutiny.

United KingdomCompliance

With the arrival of the 4th Money Laundering Directive, which came into force on 26th June 2017, has also come many changes with the aim of making the UK a more hostile place for money launderers and terrorist financers. Due to the regulations now in force, simplified client due diligence is no longer applicable in most circumstances. Firms are now obliged by Regulation 35 to have appropriate risk-management systems and procedures in place to identify when their customer (or the beneficial owner of a customer) is a Politically Exposed Person (PEP) and to manage the enhanced risks arising from having a relationship with that customer. Business relationships with family members and known close associates of a PEP are also subject to greater scrutiny.

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