March 16 2017
This guidance consultation follows the Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017 published by HM Treasury(link is external) on March 15. Our proposed guidance clarifies who should be considered a PEP, a family member of a PEP or known close associates and the steps that firms should take when dealing with higher or lower risk PEPs.
We expect firms to take a proportionate approach to meeting their money laundering obligations but there has been some evidence that firms are not applying enhanced due applied measures that were not commensurate with the risk posed by the PEP. This guidance is intended to give firms certainty on our expectations for how they treat the varying risks posed by PEPs, whether they are based in the UK, another EU member state or in a country outside the EU.