How many of you ban PEPs from opening accounts at your bank?

I do not see how to ban all PEPs from a bank.

Someone shows up at the bank to open an account with $500,000.

Besides asking them and relying on the thruthfulness of their response, how do I know whether the person was ever the Deputy Energy Minister for Bangladesh from 1981-1983?

There are no lists with all of those kinds of folks on it (that I have ever seen or even heard about).

There is a list. I've seen it but can't remember where. It lists each country and the people considered PEP's. Even the Queen of England is considered a PEP as well as the heads of state of almost every country, so being a PEP is not a negative unless you are Hussein or Milosivic.

The CIA publishes a Chiefs of State list that is kept updated. Some CIP services utilize this and also add friends and relatives gathered from various sources.

Do you really ban them? Or do you do enhanced due diligence when you set up the account? I know we do not have a policy for banning PEPs. For those of you who do ban PEPs, why do you ban them? I am just curious, maybe there is something I am not thinking of.

There are several vendors out there maintaining databases of PEPs. We just bought one.

As far as not opening accounts for PEPs, you would just put a policy in place that doesn't allow them to maintain accounts with you.

There is no rule prohibiting the bank from opening an accoung for a PEP. You just need to have the ability to identify one when opening an account and then have enhanced due dilligence to monitor the activity.