Is it a 'requirement' of all banks to check for politically exposed persons when establishing new accounts? Or, does this apply only to those offering private banking? I seem to recall reading somewhere that it was not required but suggested that PEP checks be performed. Can anyone clear these muddied waters for me?

Not a requirement per se, but your risk assessment should determine whether or not your institution would likely establish or have accounts with PEPs.

This recent article on Complianceheaquarters.com talks about PEPs. It may shed some more light on the subject.

On page 154 of the BSA/AML Exam manual, it says

"Banks should specifically identify PEP accounts and assess the degree of risks involved, which will vary." It also lists the information that should be gathered from PEPs at account opening.

Then in Appendix H on page 310, it lists the Request Letter items that you may be asked for concerning PEPs:

"Make available copies of policies, procedures, and processes specific to politically exposed persons (PEPs). Policies should include the bank’s definition of a PEP as well as procedures for opening PEP accounts and senior management’s role in the approval process for opening PEP accounts.

List of accounts in the name of or for the benefit of a PEP. List should include the country of residence of the PEP, the account balances, and the average number and dollar volume of transactions per month.

List of the information systems or other methods used to identify PEP accounts.

Management reports used to monitor PEP accounts, including reports for identifying unusual and suspicious activity."

These don't say anything about being limited to private banking.