Aall Trust & Banking
AB Ukio Bankas
Aon Insurance Managers
Athena Trustee Services
British Aerospace
Banco Atlantico
Banco Azteca
Banco Colpatria
Banco Credito Inversiones
Banco del Bajio
Banco General
Banco Promerica
Banjercito
Bank of the Bahamas
Butterfield Bank
Bank of Saint Lucia Int.
Bank United
Bank Vontobel
Banorte
Barrington Investments
Belize Bank
Bodden Financial Services
BPD Bank
Britannia Consulting
BVI Financial Services Commission
Cardinal International
Caribbean Corporate Services
Cayman National Bank
China Construction Bank
Cititrust Belize
City National Bank
Commercebank
Community Capital Bank
Crescent Corporate Services Ltd.

Politically Exposed Persons

"Politically Exposed Persons" (PEPs) are considered high risk in today's regulatory environment. Regulation requires enhanced due diligence when conducting business with Politically Exposed Persons, particularly when they become part of Private Banking. Heavy fines have been imposed on financial institutions, that have conducted business with PEPs without following adequate Know Your Customer procedures and enhanced due diligence processes. Since September 11, 2001 more than 100 countries have changed their Anti Money Laundering laws, making the fight against corruption a central element of the new legislation.

This raises two questions:

1. What is a Politically Exposed Person?
2. What are the expectations for an organization that deals with Politically Exposed Persons?

While there is no global definition for a PEP, the Financial Action Task Force (FATF) issued guidelines, in which the term Politically Exposed Person was defined. Local legislations like the USA Patriot Act or the European Union Directive use similar definitions, typically consisting of the following five layers.

• current or former senior official in the executive, legislative, administrative, military, or judicial branch of a foreign government (elected or not)
• a senior official of a major foreign political party
• a senior executive of a foreign government owned commercial enterprise, being a corporation, business or other entity formed by or for the benefit of any such individual
• an immediate family member of such individual; meaning spouse, parents, siblings, children, and spouse's parents or siblings
• any individual publicly known (or actually known by the relevant financial institution) to be a close personal or professional associate.

The interpretation of each of these layers varies from country to country. Some jurisdictions focus only on Foreign Political Figures. Some countries limit the definition to the national level, some include regional Politically Exposed Persons. While there might be slight variations of the five layers above, the expectations for an organization doing business with Politically Exposed Person are universally similar.

The following two-step process is international standard.

1.  Identify the PEPs amongst your clientele
2.  Make sure that funds managed by your organization on behalf of the Politically Exposed Person do not derive from a corrupt source

This two-step process requires organizations to use an innovative approach to determine the PEPs amongst its clients. A global PEP database covers more than 240 countries, faces different languages, needs to be maintained constantly and consequently contains a lot of data. WorldCompliance has built such a database, containing more than 420,000 profiles of Politically Exposed Persons, their family members and close associates, and maintains this data on a real time basis. Seven research centers on four continents permanently research for content, averaging more than 25,000 new profiles and more than 5,000 updated profiles a month.

As a leading provider for information on PEPs WorldCompliance even offers portrait photographs as a fully integrated feature of the profile. 

Here is what a screenshot might look like: