The Wolfsberg Group has updated its 2008 FAQs on PEPs. The new guidance clearly positions the PEP control framework within the risk based approach, and suggests an appropriate tailored manner of dealing with PEPs. It notes that although the definition of PEP is becoming wider, it is still appropriate for financial institutions to focus their effort on those who pose the highest corruption risk. It also encourages Governments to issue lists that are relevant to their jurisdictions which highlight their expectations and enshrine the risk based approach in their supervision, and for NGOs to highlight the most corrupt regimes. It calls for greater use of tools like unexplained wealth orders and asset seizure. The FAQs acknowledge that there is still no globally accepted definition of a PEP and note the difficulties firms face in assessing family members and close associates – and suggest that governments are in the best position to make these lists to help the regulated community. It also notes that it will not always be necessary to treat a PEP’s close family and close associates also as PEPs. The rest of the guidance addresses how firms should assess the risks that any given PEP presents and the due diligence that should result. Finally, the questions look at PEP screening and declassification.
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