The Financial Action Taskforce (FATF) defines a Politically Exposed Person as being “someone who is or has been entrusted with a prominent public function.” Well, being entrusted with giving gifts to all the children in one night could certainly be classed as a prominent public function but is he really a PEP?
Let’s have a look at some of the things we should consider if we are assessing Santa as a PEP:
Name: Well, Mr S. Claus has quite a few names all over the globe, his names vary because of diversity in cultures and traditions across the world. Let’s see there is St Nicholas, St Nick, Kris Kringle, Pere Noel, Father Christmas, Babbo Natale and Ded Moroz to name but a few. This is where our fuzzy matching may come in handy, and from a review of the sanctions list, he certainly doesn’t appear any of them out there.
Address: Lapland or the North Pole but which one is correct? We certainly can’t do a home visit to check Santa’s address (there are after all many people purporting to be Santa out there) and I’m pretty sure he doesn’t need a driving licence for those reindeers. So, what should we do? More questions are needed from the big man himself.
Location of the business: Santa’s work is global. So, does this make him an international PEP if one at all?
Who are family members/close associates: Mrs Claus, Dasher, Dancer, Prancer, Vixen, Comet, Cupid, Donner, Blitzen and of course Rudolph……oh and some elves. Although we aren’t sure how many elves there are let alone name them! Mrs Claus also is known by a fair few names, throughout the years she has apparently been referred to as Rebecca, Mary, Jessica, Layla and Martha. Fuzzy matching again will be our friend.
Santa is a mysterious figure who only enters public life in December each year, and whilst, enhanced due diligence would need to be done if Santa really did want to be our customer, taking a pragmatic, risk based approach to his assessment do I really think Santa is a PEP?
No, I don’t.
Good old Santa, is as far as I know not political, he doesn’t wade in, sending inappropriate tweets on world issues, he isn’t a head of state (just maybe Head of Christmas) and he isn’t a member of parliament. Santa’s only real influence is on children’s behaviour - the hope of presents if you’re ‘nice’ or coal if your ‘naughty’ (and no-one really hopes for that!) - he is the personification of the Christmas spirit.
Kind, jolly, generous, he doesn’t want anything in return for his gift-bringing kindness just good will to all men. We could search far and wide for negative news on Santa to help us in our quest to determine if Santa is a higher risk to money laundering and corruption, but the truth is there isn’t any.
Santa is who we should all strive to be not only at Christmas but all year long:
- Be present
- Send peace
- Be kind