On 16 February, the House of Commons Library published a briefing paper observing that FATF in December 2018 rated the UK as  “compliant” with its main recommendation on PEP, noting that “all criteria are met”.  However, it also notes that, in November 2021 a number of peers raised concerns that firms were still imposing disproportionate due diligence requirements on them and their families.

Any modest contributions for my time and ongoing expenses are welcomed!  I have a page where you can do so, and where one-off contributions start as low as $3, at

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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