- 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, Bar No. SYA2015211, Attorney at Law. The author is the first Online Lawyer based in Trinidad and Tobago. She has clients in Guyana, St Vincent, Barbados, the British Virgin Islands and North America. She specializes in Corporate Law and Anti-Money Laundering Compliance. She helps clients to start their Online Business Empire.
ANTOINETTE SYDNEY LAW OFFICE: MONTROSE MAIN ROAD CHAGUANAS, TRINIDAD AND TOBAGO
Consultation fee is $300 TTD per hour.
I am a Certified Professional in the following areas:
Anti-Money Laundering and Financial Crimes;
Fraud Risk Management;
Anti-Money Laundering (AML) Training for staff, directors;
Anti-Money Laundering Audits;
Compliance Program drafting;
Consulting services and much more.
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Ebooks on Sale:
- How to Change the Business Name of a Sole Trader
- How to De-Register a Sole Trader Business
- How to Register a Partnership
- How to Change from a Sole Trader Business to a Limited Liability Company
- How to Register a Limited Liability Company
- How to Change the name of a Limited Liability Company
- How to Dissolve a Limited Liability Company
- How to Register an External Company
- How to prepare Annual Returns for an External Company
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