PEP and sanction checks

Sanctions checking has been a pre-requisite for all regulated firms for some time to ensure that they do not enter into any transactions with or provide any services to any proscribed persons, in contravention of sanctions rules. The Financial Conduct Authority (FCA) has also expanded the checklist to encompass Politically Exposed Persons (PEPs).

It is an area of regulatory risk which is subject to increasing scrutiny by the FCA and other regulatory authorities. It is difficult to ensure that as a firm you are 100% compliant with the rules, as it is an ever moving target.

We offer a discrete PEPs and Sanctions checking service as part of the in depth due diligence process firms are required to undertake on a mandatory basis, either when onboarding a new customer or as part of a regular compliance review of their client base. For larger regulated firms, this checking process may be either automated or semi-automated. For smaller firms, however, there is likely to be a proportionately larger degree of manual intervention in the process.

Our assistance in this area covers the following (non-exhaustive list):

  • Enabling clients to implement the necessary policies, procedures and processes from scratch;
  • Undertaking a review of a firm’s compliance with the rules; and
  • Remedial work on a firm’s existing policies, procedures and processes on PEPs and Sanctions Checking to ensure that they are fully aligned to the FCA’s expectations.

Our services in this area are supported by a worldwide network of anti-money laundering and investigative assets and resources. With significant experience within the firm as investigative and anti-money laundering practitioners, we have both the capacity and flexibility to deliver bespoke and complex requirements, including anti-money laundering or anti-bribery training, complete financial crime programme gap analysis and overhaul to complex international investigations.

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