As those of you who work within compliance will already know, Politically Exposed Persons (PEPs) are a key risk area. You must be able to recognise these customers so appropriate controls can be implemented when you establish or maintain a business relationship.
Defined at a high level by the Financial Action Task Force (FATF) as an ‘individual who is or has been entrusted with a prominent public function’, there are also a number of more detailed PEP definitions from FATF. We’ve dropped these into a wordsearch. Can you find them all?
To get you started, the words you are looking for are listed below the wordsearch. They might appear vertically, horizontally, diagonally – forwards or backwards.
The words are all found individually in the grid, but some you will need to combine to get the correct answer (e.g. ‘for’ and ‘example’ would make ‘for example’).
BUT – there are a few other words in there too that look plausible but don’t count as correct…! See if you can find them, but then make a decision on which correctly form the PEP definitions we have asked for.
Cheat mode: if you want some help, these are drawn from the June 2013 FATF Guidance on PEPs, in relation to Recommendations 12 & 22. You can find it here.
Scroll down to see the correct answers....
- International Organisation
- Family members
- Close associates
There are, of course, more details under each of these headings – you should check the FATF Guidance mentioned above for more information on these. You’ll find this on pages 3-5.
Incorrect answers (and why)
This was a bit sneaky! These are incorrect for the purposes of this quiz as the FATF definitions referred to explicitly state that the definitions do not cover middle ranking or junior officials.
- Prominent Public Functions
That’s the high level catch-all, used by the United Nations Convention Against Corruption (UNCAC) in Article 52. FATF has adopted this meaning in its glossary definition, but it’s not what we were looking for here.
These are organisations. Sorry, another sneaky one!
If you want to learn more interesting stuff about PEPs, high risk customers, money laundering risk and beyond, take a look at our range of ICA qualifications, covering both financial crime and regulatory compliance.
By following us on LinkedIn, Facebook and Twitter you’ll stay up to date with the latest developments in governance, risk, anti-money laundering and financial crime prevention, and the professional qualifications we offer.