High-risk customers, including politically exposed persons (2024)

Regulated firms are required to take a risk-based approach to customer due diligence and ongoing monitoring under the Money Laundering Regulations.

Firms should conduct enhanced due diligence (EDD) and enhanced ongoing monitoring in higher-risk situations. Situations that present a higher money-laundering risk might include, but are not restricted to:

  • customers linked to higher-risk countries or business sectors
  • customers who have unnecessarily complex or opaque beneficial ownership structures
  • transactions thatare unusual, lack an obvious economic or lawful purpose, are complex or large or might lend themselves to anonymity

The regulations also require that EDD measures should be applied where the customer is not present, in correspondent banking relationships where the correspondent bank is outside the European Economic Area, and for politically exposed persons (PEPs).

Politically exposed persons

Politically exposed persons (PEPs) are individuals whose prominent position in public life may make them vulnerable to corruption. The definition extends to immediate family members and known close associates.

The full definition of a PEP is set out in the Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017. We have included moredetails in ourFinancial crime guideon how firms can identify, assessand mitigatetheir risks in these areas.

Guidance is also produced by the Financial Action Task Force regarding PEPs which provides standards for financial institutions when dealing with these types of customers.

Page updates

: Editorial amendment page update as part of the website refresh

: Link changed Financial crime guide

As a seasoned expert in financial regulations and anti-money laundering practices, my extensive experience and in-depth knowledge uniquely position me to dissect the intricacies of the article on regulated firms' risk-based approach to customer due diligence under the Money Laundering Regulations.

The article emphasizes the importance of regulated firms adopting a risk-based approach to customer due diligence and ongoing monitoring. This approach is a cornerstone in combating money laundering and terrorist financing, crucial aspects of financial crime prevention. Let's delve into the key concepts highlighted in the article:

  1. Risk-Based Approach:

    • Regulated firms are mandated to adopt a risk-based approach, implying that the level of scrutiny and due diligence should be commensurate with the perceived risk associated with a customer.
  2. Enhanced Due Diligence (EDD):

    • Higher-risk situations necessitate enhanced due diligence and ongoing monitoring. This involves a more thorough investigation and scrutiny of customers and transactions that exhibit characteristics associated with a higher risk of money laundering.
  3. Higher-Risk Situations:

    • Various situations are deemed higher-risk, including customers linked to higher-risk countries or business sectors, those with complex beneficial ownership structures, and transactions that are unusual, lack an obvious economic or lawful purpose, are complex or large, or might allow for anonymity.
  4. Correspondent Banking Relationships:

    • Enhanced due diligence measures are required in correspondent banking relationships, especially when the correspondent bank is located outside the European Economic Area.
  5. Politically Exposed Persons (PEPs):

    • The article emphasizes the significance of applying enhanced due diligence measures for politically exposed persons (PEPs). PEPs are individuals in prominent public positions who may be vulnerable to corruption. This definition extends to immediate family members and close associates.
  6. Financial Action Task Force (FATF) Guidance:

    • The Financial Action Task Force provides guidance on dealing with PEPs, setting international standards for financial institutions in managing the risks associated with these high-profile customers.
  7. Legal Framework:

    • The legal framework for these regulations is outlined in the Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017.
  8. Updates and Resources:

    • The article mentions updates, including editorial amendments and links to additional resources such as the Financial Crime Guide. The guide likely provides detailed insights into identifying, assessing, and mitigating risks in areas related to financial crime.

In summary, the article underscores the critical role of a risk-based approach, enhanced due diligence, and vigilance in high-risk situations, especially concerning politically exposed persons. Compliance with these regulations is not only a legal requirement but a fundamental aspect of safeguarding the integrity of financial systems against illicit activities.

High-risk customers, including politically exposed persons (2024)

FAQs

Why is PEP considered high-risk? ›

PEPs are at a higher risk for corruption, money laundering, terrorist financing, and bribery related to the nature of the influence they hold based on their position. The following are examples of politically exposed persons: Current or former government officials.

Who shall be considered as high-risk customers? ›

Higher Risk Customers are those who are engaged in certain professions or avail the banking products and services where money laundering possibilities are high. Moreover, Financial Institutions conduct enhanced due diligence (EDD) and ongoing monitoring for higher risk customers.

Which of the following would be considered a high-risk customer? ›

Stolen Credit Card Customers. Money Laundering Customers. Multi-Accounting Customers. Customers from High-Risk Countries.

What is a high-risk customer classification? ›

High-risk customers are individuals or entities that, due to specific characteristics or circ*mstances, pose an elevated level of risk for businesses or financial institutions. These customers may be more likely to engage in activities associated with money laundering, financial crimes, or other illicit behavior.

Who is considered to be PEPs? ›

In financial regulation, a politically exposed person (PEP) is one who has been entrusted with a prominent public function. A PEP generally presents a higher risk for potential involvement in bribery and corruption by virtue of their position and the influence they may hold.

Is a PEP a red flag for money laundering? ›

Blog / Political Exposed Person Red Flag and Indicators

They are considered high-risk customers due to their potential involvement in financial crimes such as corruption and money laundering.

What are the five high risk customer groups? ›

These people include pregnant women, their unborn and newborn babies, the elderly and people whose immune systems have been weakened by illness or drugs (for example: cancer patients, organ transplant recipients, and people on drugs like cortisone).

What factors do you consider when determining a customer as high risk? ›

Typically, companies evaluate factors such as age, country of origin, and the nature of the business relationship to assess a customer's risk. This includes examining the customer's identity, location, the source of their funds, and how they intend to use those funds.

What are high risk users? ›

High-risk users are the top quartile of users in an organization who have had at least one instance of risky behavior, or event. These risky users are responsible for: 41% of all simulated phishing clicks. 30% of all real-world phishing clicks.

What are the 4 risk classification categories? ›

The 4 main categories of risk are financial risk, operational risk, compliance risk, and legal risk. Financial Risk: This category includes risks related to the financial performance of a business.

Which of the following is not considered a high risk customer in AML? ›

Entities that are exempted from the threshold transaction reporting by FIU if such entities are not considered as high risk. Government bodies, government owned companies, regulatory and supervisory bodies, semi government corporations, Banks and Financial Institutions licensed by central bank etc.

What are the top 5 risk categories? ›

As indicated above, the five types of risk are operational, financial, strategic, compliance, and reputational. Let's take a closer look at each type: Operational. The possibility that things might go wrong as the organization goes about its business.

What category of risk is PEP? ›

Individuals in leadership positions within international banks or financial oversight committees are classified as PEPs. Their roles involve overseeing financial transactions and dynamics between countries and multinational corporations, placing them in a high-risk category.

What is the risk of taking PEP? ›

PEP can cause mild side effects, including nausea, upset stomach, fatigue and headaches. These symptoms often get better or go away after the first week of taking PEP. To prevent nausea, take PEP with a snack or before bed to make nausea less noticeable. To relieve nausea, try ginger candy or peppermint tea.

What is the risk categorization for PEP? ›

PEPs can be split into three main risk categories: low, medium, and high. The first step to determining an entity's risk evaluation criteria is to learn which category applies to them: Entities with minimal influence and exposure. Usually includes regional government officials, such as mayors.

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