New AML Guidance

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    Is anyone able to tell me how I am able to ascertain if a client is a close associate or family member of a PEP?

    The HMRC says I *will* establish this. Maybe I have to inject all clients with sodium pentothal before quizzing them?


    Not Surprised

    If you don’t have a electronic provider such as LexisNexis you’d need to ask them and also Google them. Selling to/for a PEP isn’t anything that you’d usually need to submit a SAR for, you’re just required to do EDD and monitor so it’s ok to ask them straight out and you could do this on a vendor/buyer fact find.

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