Any individual that is considered a Politically Exposed Person (PEP) in their own capacity or by association. PEP refers to individuals who hold positions of power, status, or influence in government, high-ranking political parties, the military, state-owned enterprises, or those closely associated with such individuals. Due to the nature of their positions, PEP may be at risk of engaging in illegal activities such as corruption, bribery, and money laundering. Therefore, financial institutions, businesses, and organizations typically onboard clients involved with political risks with enhanced due diligence measures and stricter risk assessment to ensure compliance with anti-money laundering and anti-corruption laws and regulations.

Financial institutions may, based on a risk-based approach, decide not to adopt or continue to adopt enhanced due diligence (EDD) measures for clients or beneficial owners who are former politically exposed persons (Former PEP). This decision requires approval from senior management and is contingent upon the Former PEP no longer posing a high money laundering/terrorist financing risk.

Financial institutions should conduct appropriate assessments of money laundering/terrorist financing risks associated with the PEP’s former status and determine whether the former PEP no longer poses a high money laundering/terrorist financing risk. Various risk factors should be considered in this determination, including but not limited to:

(a) The influence that the individual can still exercise;

(b) The rank of the position held by the individual as a political figure; and

(c) The connections (either past or present) with the succeeding political figures (For instance, formal connections through appointment, or informal connections where the individual essentially handles the same important matters).  

Any individual or entity that is or has formerly been subject to sanctions at international, regional, or national levels. This definition encompasses individuals or entities that have been identified by international organizations, regional bodies, or national authorities as violating international law, regional laws, or national regulations. Sanctions are typically punitive measures imposed on those involved in illicit activities, human rights violations, support for terrorism, drug trafficking, arms trading, and other similar actions. International sanctions are typically implemented by organizations such as the United Nations, the European Union, the United States, and other national entities. The purpose of these sanctions is to promote international security, maintain international order, and curb illegal activities. Sanctions can include measures such as asset freezes, travel bans, trade restrictions, and other actions aimed at restricting the actions and resources of sanctioned individuals or entities.

Any individual or entity that has been reported in official or media sources to be involved in a crime that falls under one or more of the following categories – terrorism, financial crime and fraud, modern slavery, organised crime, bribery and corruption, and cybercrime.

• Terrorism: Individuals or organizations involved in organizing, supporting, or carrying out terrorist activities.
• Financial crimes and fraud: Individuals or organizations engaged in fraud, money laundering, scam, and other criminal activities related to the financial system.
• Modern slavery: Individuals or organizations involved in human trafficking, exploitation of labor, forced labor, and other forms of modern slavery.
• Organized crime: Individuals or organizations involved in organized criminal activities such as organized illegal trafficking, smuggling, drug trading, etc.
• Bribery and corruption: Individuals or organizations involved in bribery, corruption, and other corruptive activities.
• Cybercrime: Individuals or organizations involved in cyber-attacks, cyber fraud, data theft, and other cybercriminal activities.

These categories encompass a range of serious criminal activities that pose threats to social security, financial stability, and individual rights. These criminal activities are rigorously combated and prosecuted at the international, national, and regional levels.

Any person that has been declared as bankrupt or insolvent in the United Kingdom or in Ireland. This declaration is made by the courts or relevant legal institutions in the United Kingdom and Ireland and results in the financial affairs of the individual or entity being regulated and managed. The credit history of such individuals has been negatively affected, making it difficult for them to obtain loans, credit cards, leases, or engage in other financial transactions in the future. Financial institutions should assess their credit risk and financial status.

Natural or legal persons that were profiled based on Acuris Risk Intelligence’s legacy data model and can be linked to outdated red flags, such as former PEP status, reputational risk, or regulatory measures that are no longer in force. These Natural or legal persons may have been flagged in the past as having risks or issues, but over time or for other reasons, these risks may or may not have become outdated or no longer exist. This information may or may not be outdated, and financial institutions should not solely rely on it as a basis for decision-making. Further review and updates should be conducted to assess and make informed decisions.

Any individual or entity that has been fined or in some other way subject to action by any financial regulatory bodies or law enforcement authorities. The reputation of such individual or entity has been negatively impacted. These records may be taken into consideration in financial transactions, credit applications, business collaborations, and other related areas. Financial institutions should assess their risks and credibility and make appropriate decisions to mitigate the relevant risks.

Any individual that has been disqualified as acting as a director of a company in the United Kingdom. The information about these individuals, including the reasons for disqualification, the effective date, the duration of disqualification, and the names of relevant courts or institutions, are made public. Financial institutions should consider the background information of such individuals and consider the associated risks when assessing establishing business relationships with them.

Profiles of companies in which the state exercises control or ownership, typically managed and supervised by government agencies or relevant state-owned asset management institutions. The state has significant influence over the decision-making and management of state-owned enterprises, with national economic and political factors often serving as the primary objectives for their operations.

Enterprises owned or controlled by politically exposed persons (PEPs). These enterprises can take the form of companies, organizations, funds, or other types of economic entities directly or indirectly owned or controlled by PEPs. These enterprises may obtain special treatment, privileges, or benefits through the relationships and influence of the linked PEPs. It is important for financial institutions to pay attention to enterprises owned or controlled by PEPs as they may involve risks related to anti-money laundering.

Family members and individuals who have a close business relationship or beneficial ownership with PEPs. Typically family members or individuals who are not PEPs in their own capacity but serve on a board of directors alongside with the associated PEPs.

Based on FATF, Close Associates are considered to be: partners outside the family unit (e.g. girlfriends, boyfriends, mistresses); prominent members of the same political party, civil organization, labor or employee union as the PEP; business partners or associates, especially those that share (beneficial) ownership of legal entities with the PEP, or who are otherwise connected (e.g., through joint membership of a company board).

In the case of personal relationships, the social, economic, and cultural context may also play a role in determining how close those relationships generally are.

Contains the archive of anonymized due diligence reports on VIP casino players and online casino players. Financial institutions doing business with gambling risk persons can create various operational risks due to the nature of the gambling industry. Some of the risks include: money laundering, fraud and illegal activities, regulatory compliance, reputation risk, and credit risk. To mitigate these operational risks, financial institutions need to implement robust risk management frameworks, conduct thorough customer due diligence, monitor transactions for suspicious activities, comply with regulatory requirements, and establish effective internal controls and reporting mechanisms.