The FCA expects that firms take appropriate but proportionate measures in meeting their financial crime obligations.
The MLRs set out that all firms must apply a risk sensitive approach to identifying PEPs and then applying enhanced due diligence measures.
The legislation and guidance clarifies that a case by case basis is required with the risk assessed of individual PEPs rather than applying a generic approach to all PEPs.
The treatment of politically exposed persons for anti-money laundering purposes
The guidance provides clarity on how firms should apply the definitions of a PEP in the MLRs in a UK context.
This includes providing that firms should only treat those in the UK who hold truly prominent positions as PEPs and not to apply the definition to local government, more junior members of the senior civil service or anyone other than the most senior military officials. As such it is unlikely in practice that a large number of UK customers should be treated as PEPs.