Thread Options
|
#313196 - 02/07/05 02:45 PM
PEPs
|
Diamond Poster
Joined: Jun 2004
Posts: 1,927
NYC
|
I would like your feedback on the issue of PEPs. We are a small community bank with branches in NYC and New Jersey. Our customers are small businesses and individuals who reside in the area; we do not open accounts for non US persons or businesses. Our auditors have commented that we should check new accounts for PEPs and, also, should check sales of official checks and money orders for PEPs. On the issue of new accounts, while I understand that ehanced due dilligence is required when a customer is a PEP, given our customer base I really see no need to even check new accounts. On the issue of official check and money order sales, I believe that the auditor is way off base. Any comments/guidance on these issues would be appreciated.
|
Return to Top
|
|
|
|
#313198 - 02/07/05 02:56 PM
Re: PEPs
|
Diamond Poster
Joined: Jun 2004
Posts: 1,927
NYC
|
Kaybee, thats a good point. We do have a small number of accounts for foreign students. That said, how do we go about checking, since I know of no definitive listing?
|
Return to Top
|
|
|
|
#313199 - 02/07/05 03:25 PM
Re: PEPs
|
Power Poster
Joined: Apr 2001
Posts: 4,828
Between the lines
|
I feel really dumb asking this, but what is a PEP?
_________________________
NOLA is my Beach!
|
Return to Top
|
|
|
|
#313200 - 02/07/05 03:40 PM
Re: PEPs
|
Anonymous
Unregistered
|
PEP Politically Exposed Person. Presidents (leaders) of countries, High ranking officials, etc.
|
Return to Top
|
|
|
|
#313203 - 02/07/05 04:37 PM
Re: PEPs
|
Diamond Poster
Joined: Jun 2004
Posts: 1,927
NYC
|
Kaybee, the problem with using the CIA list is that it does not include family members and close associates so for this we would have to "Google" them and this would be like looking for a needle in a haystack.
|
Return to Top
|
|
|
|
#313205 - 02/07/05 05:04 PM
Re: PEPs
|
Anonymous
Unregistered
|
Should every account be checked against this list?
|
Return to Top
|
|
|
|
#313208 - 02/07/05 08:52 PM
Re: PEPs
|
Diamond Poster
Joined: Jun 2004
Posts: 1,927
NYC
|
Kaybee, no further ideas. You are doing all that could be reasonably expected (perhaps more so). I assume that this approach is OK with your examiners?
|
Return to Top
|
|
|
|
#313209 - 02/07/05 09:21 PM
Re: PEPs
|
Anonymous
Unregistered
|
I am still confused..where do you find out who a PEP is? Is it the same as the SDN list of persons or countries..or is this a different list the requires different software... and from a new account perspective..can we just have a question the customer could answer yes or no to... to satisfy this issue...or is the bank's burden to verify? Thank you.. the PEP thing just came up in an audit and has us all scrambling for a solution>>>
|
Return to Top
|
|
|
|
#313210 - 02/07/05 09:50 PM
Re: PEPs
|
Diamond Poster
Joined: Jun 2004
Posts: 1,927
NYC
|
Unfortunately there is not an official list. As Kaybee indicated earlier, there is a CIA list of government officials, but this does not include family members, associates, etc. This is another case of the government imposing requirements that are difficult to comply with. The only saving grace, in my opinion, is that if the customer is a US person, with a local address, SS# or ITIN, there is little chance that he is a PEP. Convincing your auditor or examiner of this, however, might be difficult.
|
Return to Top
|
|
|
|
|
|