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PEP Identification

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Do you have to ask every new customer if he/she is a PEP during your CIP/Risk Assessment questioning? If not, can you suggest how to identify a PEP?

There is no one size fits all process. Many banks ask the PEP question after determining citizenship status. It is not foolproof, as a US citizen could be a close relative or associate of a politically exposed person, but based upon a risk assessment, a bank may determine that its highest exposure to PEPs is through resident or non-resident aliens.

First published on 4/12/10

First published on 04/12/2010

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