OK

I'm NOT your compliance guru by a long shot, however...i need to understand something. Is it mandatory to be asking the customer due diligence questions such as are you a foreign government official....during the account opening process or does asking these questions depend on to some degree the risk level of my instituion?

Since there is no PEP list, you won't know if you don't ask.

Some EDD questions would be triggered by risk, but others would be routine.

From the great stone tablets (the Manual):

PEP accounts are not limited to large or internationally focused banks. A PEP can open an account at any bank, regardless of its size or location. Banks should have risk-based procedures for identifying PEP accounts and assessing the degree of risks involved, which will vary

What they are saying is that you could not dismiss the possibility of banking a PEP just because you were located in northwestern Nebraska. However, in Florida, well, Florida is the "A League" for AML compliance. Geography and cultural diversity dictate you make some attempt to identify PEPs at account inception at least. I dealt with a banker in the panhandle last year who found a member of the Saudi family (Americanized name, no less) on his wire transfer log.

In Mount Dora you may get away with: Are you, any of your family members, or close associates affilated with the government of a foreign country? In Miami, that's just foreplay.

It's not that it's mandatory, it's just that you have to do it.

Lol

I...... get it

Thanks to you both