The following steps are required to conduct Enhanced Due Diligence (EDD) on Politically Exposed Persons (PEPS):
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- Ensuring that appropriate risk-management systems are in place to determine whether the customer or the beneficial owner is a PEP, or immediate family member or close associate of a PEP (Reg. 20 (2);
- Obtaining senior management approval BEFORE establishing (continuing, for existing customers) the business relationship (Reg 20 (4);
- Ensuring that reasonable measures are taken to determine the source of wealth and source of funds (Reg. 20 (5); and
- Conducting enhanced on-going monitoring of the business relationship (Reg. 20 (5).
The author is an attorney at law based in Trinidad . She specialises in Anti Money Laundering and Fraud and Risk Management.
Website : http://asydneygroup.com
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