US: REGULATORS’ JOINT STATEMENT ON DUE DILIGENCE REQUIREMENTS FOR CUSTOMERS WHO MAY BE CONSIDERED PEP

On 21 August, the Board of Governors of the Federal Reserve, the Federal Deposit Insurance Corporation (FDIC), FinCEN, the National Credit Union Administration (NCUA), and the Office of the Comptroller of the Currency (OCC) issued a joint statement to address due diligence questions raised by banks related to Bank Secrecy Act/Anti-Money Laundering regulatory requirements for customers whom banks may consider to be politically exposed persons (PEP).  Banks had requested clarification on how to apply a risk-based approach to PEP consistent with the customer due diligence (CDD) requirements contained in FinCEN’s 2016 CDD Final Rule.  Note that the various bodies do not interpret the term “politically exposed persons” to include US public officials.

https://www.fdic.gov/news/press-releases/2020/pr20092a.pdf

 

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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