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Does Your Business Convey the Right Message for Sanctions, PEPs & SIPs?

31st July 2013

As Anti-Money Laundering (AML) requirements and the consequences of those failing to comply become yet more prevalent it’s increasingly clear that the legal sector is sitting up and taking notice. However, when the subject of PEPS (Politically Exposed Persons), Sanctions and SIPs is raised there are still some who are willing to consider such risks as fictional entities, never likely to darken their door. So, can you guarantee that PEPs are not instructing fee earners and putting you and your business at risk?

Dealing with any person or business named on a Sanctions List means a fine or imprisonment for the person responsible for company’s compliance – normally the MLRO.  It is advisable to check all new clients (businesses and individuals) against official Sanctions and PEP lists.

All fee earners should be aware of the measures needed to identify they are dealing with a PEP and what they are legally required to do. Firms are required to have in place a risk based process for such threats and once discovered they should:

  • seek senior management approval for the business relationship
  • take adequate measures to establish source of funds and source of wealth
  • conduct closer on-going monitoring of the business relationship.

E-verification providers such as SmartSearch can deliver further information about such individuals and all client records are subject to daily monitoring against updates to the Sanctions and PEP lists The final AML certificate clearly shows whether an individual appears on such a list.

Firms who turn a blind eye to the activities of corrupt PEPs and try to simply ‘manage’ the relationship face a risk of serious sanction.


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