On 28 February, Allen & Overy published an article saying that PEP are considered to be more vulnerable to corruption so those who deal with them are often obliged to exercise a higher degree of caution.  Sometimes, it says, it is obvious whether someone is a PEP, or if a corporate customer is linked to a PEP.  But it is not always that clear, particularly in relation to those individuals who work at commercial enterprises which are owned or partially owned by a State.  The article stresses that, PEP status does not of course mean that transactions by that individual are inappropriate.  However, being a PEP does put a customer into a higher risk category.  The article says that a recent Court of Appeal decision in the UK has provided guidance on the meaning of ‘State-owned enterprise’ (on which there was a surprising lack of any previous authority) and PEP.  This ruling is said to help those who have to decide whether a person working at a part State-owned entity falls in that category.

If you’d like to help me buy that (badly needed) new laptop or, even better, a new desktop to replace the one now 5,000 miles away –



Author: raytodd2017

Chartered Legal Executive and former senior manager with Isle of Man Customs and Excise, where I was (amongst other things) Sanctions Officer (for UN/EU sanctions), Export Licensing Officer and Manager of the Legal-Library & Collectorate Support Section

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