DIFFERENT ANGLE by Kenneth Rijock
We all know the textbook (FATF, Wolfsberg et al) generally-accepted definitions of a Politically Exposed Person, or PEP. A senior governmental, military, non-profit, NGO, or charitable official, or one who performs an important official or governmental function. The trouble is, corrupt government leaders can read compliance manuals, too. They know very well where the term kicks in, and who the classic definitions exclude from PEP status. So what will they do? Tunnel under your fixed definition, and defeat you, by depositing in your bank bribe money, funds looted from government treasury accounts, kick-backs, hush money, or any other form of illicit funds that they shouldn't legally have, and you shouldn't take.
- Senior military officer: Army and Air Force Colonel/Navy Captain or above, meaning general officer or flag rank.
- Senior governmental official:heads of major governmental departments or agencies, ministers, congressmen or senators, or high-ranking functionaries.
- Senior officials of non-governmental organisations: individuals with leadership, titles and authority over rank-and-file staff. They also have the ability to bind the NGO through contract, and to approve and fund budgetary items.
- Leaders of charitable entities: very senior staff, who set, and implement, policy and strategies, and who decide how contributions are spent.
- Directors and senior officers of non-profit companies: Individuals who set corporate agendas and goals, and have discretionary and budgetary spending authority.
- Government attorneys who are counsel to their ministry, agency or department.
- Senior secretaries or administrative assistants to high-ranking governmental officials.
- Unpaid outside advisers to NGO or non-profit corporations.
- Outside Directors and influential committee members of major charities.
- Army and Air Force Majors, and Navy Lieutenant Commanders who are involved in purchasing or contracting.
- Aides to general officers or flag rank officers (admirals or commodores).
- Contract officers at non-governmental organisations.
Note: Alternatively, real PEPs may use these non-PEPs as fronts to move their illicit cash, first constructing some sort of bogus Source of Funds origin, like inheritance, family wealth, lottery winnings, or some other plausible source of income. Genuine verification enquiries will look right through these contrived sources.
Source of Funds becomes a paramount consideration in deciding whether to accept the business of quasi-PEPs, just as it is with the true PEPs. Do not take short-cuts here; if they are even borderline
with any of the above categories, investigate before approving them for any new account relationship.
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