- Ensuring that appropriate risk-management systems are in place to determine whether the customer or the beneficial owner is a Politically Exposed Person (PEP), or immediate family member or close associate of a PEP (Regulation 20 (2). You may consider investing in software that will allow you to enter the name of the customer of the beneficial owner and then the software will reference this name against PEP lists, Sanctions lists.
- Obtaining senior management approval BEFORE establishing (continuing, for existing customers) the business relationship (Reg 20 (4). The rationale is to inform senior management that there is Politically Exposed Person (PEP) who is desirous of conducting business with your entity. Management can make a decision whether to accept or reject this PEPs business.;
- Ensuring that reasonable measures are taken to determine the source of wealth and source of funds (Reg. 20 (5). Source of funds refers to the origin of and activity that generated of the money that will be used to compete the purported transaction. Source of wealth refers to the entire body of assets that potentially generate income for the PEP.;
- Conducting enhanced on-going monitoring of the business relationship (Reg. 20 (5) The regulated entity must from time to time conduct searches to see if there has been any adverse news in the media about the PEP such as charges or conviction for bribery or corruption or financial crimes.
About the Author: Antoinette Sydney LLB LEC CAMLFC CFRMP is an author and entrepreneur based in Trinidad and Tobago.
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