Political exposure is a term that is frequently used in the financial sector. It refers to individuals who hold a prominent public position and may be susceptible to bribery or other types of financial crimes. Such individuals are known as politically exposed persons (PEPs). PEPs can be either domestic or foreign. Domestic PEPs are those who hold high-ranking public positions within their own country, while foreign PEPs hold similar positions in other countries. In this blog post, we will explore the differences between domestic and foreign PEPs, the risks associated with them, and the steps that financial institutions can take to manage these risks and comply with regulations.
Domestic Political Exposed Persons (PEPs)
The Financial Action Task Force (FATF) provides guidance on identifying and managing PEPs. Domestic PEPs are defined as high-risk individuals who hold positions of power within their country of residence and have a connection with a financial institution as its client. Such individuals include senior politicians, heads of state-owned companies, and senior military officials. While factors such as place of residence do not determine the type of PEP, they can be considered when assessing the level of risk associated with the Domestic PEP. It is important to note that financial institutions are more likely to have Domestic PEPs than Foreign PEPs as clients. Some countries publish lists of Domestic PEPs, but the FATF does not require this and sees such lists as potential challenges for effective implementation. Countries may choose to publish either a list of PEP functions or a list of real names. Understanding the differences between Domestic PEPs and Foreign PEPs can help financial institutions better manage their risks when dealing with PEP clients.
Foreign Political Exposed Persons (PEPs)
The FATF defines Foreign PEPs as individuals who hold important public positions on behalf of a foreign government, whose positions are different from the government where the financial institution is located. This includes:
- Head of government
- Vice president
- Council of ministers
- Members of the government's executive board
- A senior soldier
- Central bank manager
- Director of any state-owned company
- Senior officials of an important political party
Although Foreign PEPs may have previously performed the same tasks, they are still classified as high-risk and fall under the Foreign PEP category. Their place of birth, residence, or citizenship is not a factor when assessing their risk level as Domestic PEPs. As such, financial institutions need to exercise extra caution when dealing with Foreign PEPs as their risk level is higher than that of domestic PEPs. To mitigate these risks, financial institutions must conduct more thorough scrutiny of Foreign PEPs. Therefore, it is essential to note that Foreign PEPs carry a higher risk than domestic PEPs.
FATF Recommendations for Foreign PEP Identification
In addition to Enhanced Due Diligence measures, the FATF has also recommended that financial institutions should establish a comprehensive risk management framework to identify, assess, and manage the risks associated with Foreign PEPs. This framework should include the adoption of policies and procedures that outline the institution's approach to managing the risks associated with Foreign PEPs. The institution should also have an effective screening process in place to identify whether a customer is a Foreign PEP.
Moreover, it is recommended that financial institutions should conduct ongoing monitoring of Foreign PEPs' accounts and transactions to ensure that the information obtained remains up-to-date and relevant. This monitoring should include regular risk assessments, and the institution should have clear procedures in place to escalate any concerns or suspicions about the customer's activities to the appropriate authorities.
Financial institutions should also provide regular training to their staff to raise awareness of the risks associated with Foreign PEPs and how to effectively manage them. This training should cover the institution's policies and procedures, the requirements of local regulations, and the red flags that may indicate potential suspicious activity.
AML Screening for PEPs
AML screening tools are critical in identifying and mitigating the risks associated with Domestic and Foreign PEPs. These high-risk individuals have access to political power and public funds, making them prime targets for financial crimes like bribery, corruption, and money laundering. Without effective AML screening, financial institutions can unwittingly become involved in criminal activity or inadvertently facilitate the movement of illicit funds.
AML screening tools allow financial institutions to identify and verify the identities of Domestic and Foreign PEPs and assess the level of risk they pose. By screening PEPs against sanction lists, criminal databases, and politically exposed persons databases, financial institutions can assess their potential involvement in financial crime and take appropriate measures to manage the risk.
Moreover, AML screening tools help financial institutions meet their regulatory obligations by complying with international AML/CFT (Combating the Financing of Terrorism) standards set by organizations such as the FATF (Financial Action Task Force). Failure to comply with these standards can result in severe financial penalties, reputational damage, and legal consequences.
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