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AML Regulators Clarify Diligence Requirements for Politically Exposed Persons

By Katherine Mooney Carroll, Paul Marquardt, Patrick Fuller & Graham Bannon on August 31, 2020
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On August 21, the Financial Crimes Enforcement Network, together with the federal banking agencies, released a statement to clarify banks’ customer due diligence obligations for politically exposed persons. The Statement affirms that (i) there is no regulatory requirement, and no supervisory expectation, for banks’ Bank Secrecy Act / anti-money laundering programs to include “unique, additional due diligence steps” for customers who are PEPs and (ii) there is no regulatory requirement for banks to screen customers and their beneficial owners for PEPs.  Instead, the Statement confirms that PEP customers should be subject to the same risk-based approach to CDD that applies to any other customer, but that PEP status (and screening for PEPs) may be a factor in developing a customer risk profile and assessing money laundering risk.  It also reminds banks of the continued U.S. national security and law enforcement interest in detecting and combatting public corruption and other criminality involving PEPs.

Please click here to read the full alert memorandum.

Photo of Paul Marquardt Paul Marquardt

Paul Marquardt’s practice focuses on economic sanctions, anti-money laundering, foreign investment review and anticorruption issues.

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  • Posted in:
    Banking, Finance and Securities
  • Blog:
    Cleary Enforcement Watch
  • Organization:
    Cleary Gottlieb Steen & Hamilton LLP
  • Article: View Original Source

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