Under the Money Laundering Regulations 2017, in order to open work for any new client, we need to determine if any of the trustees of their organisation are ‘Politically Exposed Persons’ (PEP). Such persons generally present a higher risk for potential involvement in bribery and corruption due to their position and influence they may hold.

A Politically Exposed Person is one of the following:

  • heads of state and government
  • members of government (national and regional)
  • members of Parliament
  • heads of military, judiciary, law enforcement and board of central banks
  • top ranking officials of political parties
  • senior officials of the military, judiciary, and law enforcement agencies
  • senior officials of other state agencies and bodies and high-ranking civil servants
  • senior members of religious denominations, such as a Bishop of the Church of England
  • ambassadors, consuls, high commissioners
  • senior management and board of directors of state-owned businesses and organisations – e.g. Chair of NHS England.

Politically Exposed Persons will also include this person’s family members and known close associates.

As a potential client, if one of your trustees (or family or associates of trustees) falls into these categories, please let us know as soon as you can.