Politically Exposed Persons

We are required to be aware as to whether any of our clients are likely to be “politically exposed”.  The Financial Action Taskforce has published some guidelines to accompany the definition of who is a Politically Exposed Person (or “PEP”).

It is important to understand that being a PEP does not prevent you from being a client of the firm, but we are required by law to determine whether or not you might fall within that definition.

If you think that you might fall within one of the categories mentioned below, please speak to us at the earliest opportunity.

A Politically Exposed Person will include:

  • Individuals who are or who have been entrusted with prominent public functions by a foreign country (for example Heads of State or of Governments, senior politicians, senior government officials, judicial or military officials, senior executives of state owned corporations, important political party officials)
  • Individuals who are or who have been entrusted domestically with prominent public functions (for example Heads of State or of Governments, senior politicians, senior government officials, judicial or military officials, senior executives of state owned corporations, important political party officials)
  • Persons who are or who have entrusted with a prominent function by an international organisation (which may include members of senior management of that organisation as well as directors, deputy directors and members of the board or equivalent functions)
  • Family members of any person falling with the above definitions (either directly or through marriage or civil partnership
  • Close associates (either socially or professionally) or any person falling with the above definitions
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