Is there a definition which allows us to determine when someone is no longer a PEP? Is it s period of time? How far removed from the situation? Once a PEP always a PEP?

Any guidance is appreciated.

Thanks.

I wouldn't think it ends until their friend or relative dies or is relieved of their military or political duties. But then some connections live beyond the grave, etc.

I can't think of a hard and fast rule for removal from PEP status.
It would depend on who it was, how high the position, how high risk the country, etc.

See
http://siteresources.worldbank.org/EXTSA...me=PEPs-ful.pdf


Go to page 31 for a discussion on how long a PEP remains a PEP.

Once a PEP, always a PEP. The individual will always have a realm of influence beyond that of a "normal" person because his/her prior military or political position. What does that mean as far as the bank is concerned? That with regard to the PEP's accounts, the activity you see is commensurate with his/her current economic status, income source, etc. Just as with any other customer.

From FFIEC BSA Online Manual http://www.ffiec.gov/bsa_aml_infobase/pages_manual/OLM_087.htm