HM Govt have updated the Regulations for Domestic PEPS. The changes come into force on 10th January 2024.
Regulation 35 of the Money laundering Regulations requires a Firm to undertake Enhanced Due Dilligence when dating with a PEP.
From 10th January 2024, Firms will need to undertake a risk assessment if the Individual is a Domestic PEP. The assumption being that domestic PEPS pose a lower level of risk than non-domestic/overseas PEPS. Where the firm identifies a potential risk then Enhanced Due Dilligence should continue to be undertaken.
In any event, Firms should continue to record details of the Enhanced Due Dilligence undertaken and periodically review the account for signs of any unusual activity.
Next Steps
Review / Update risk assessments and training materials
Cascade details to fromnt line staff and provide apporpriate training where necessary
Update policies and procedures
Should you need any help do get in touch.