When Fidel Castro admitted that he was too ill to even attend his massive 80th birthday celebration, most Cubans began to get the message: Castro, who had removed himself from power when he became seriously ill, and whose health is a state secret, may soon pass away. When he does, the future of the Cuban communist government will be in doubt. Will there be a struggle for power, or even a civil war?  We cannot say, but people in Castro's inner circle must be feeling somewhat insecure this week.

Compliance officers at international banks holding funds for Cuban PEPs, Cuban government-controlled corporations, close family members of PEPs, and senior Cuban military officers may want to review the suitability of these accounts now, and to insure that Source of Funds is fully documented, and thus not an issue on accounts that your management desires to maintain.

Funds held abroad on behalf of Cuba's president and his immediate family may also be covertly transferred, but to judge by the posturing of anti-Castro Cuban exiles who will be seeking their own brand of post-Castro justice by seeking forfeiture of these funds, banks found to be holding these assets will find themselves as defendants in the world's courts. Reputation damage? Yes, in a big way.

Therefore, it may pay to review accounts of Cuban nationals at this time, to ascertain whether any may be PEPs not previously identified at the time the accounts were opened, or if any have become PEPs since they became bank customers.