The news this week that the Federal Bureau of Investigation (FBI) is investigating money missing from donations to the National Republican Congressional Committee reminds us that we must consider individuals who have access to election campaign funds to be Politically Exposed Persons, or PEPs. Long-time readers will recall that I once listed as PEPs all 47 candidates for President of the Republic of Haiti, for even the most obscure of them were receiving substantial amounts of donations from supporters and vested interests. Then there is the issue of what will become of leftover campaign funds when an opponent fails to materialise after the primary, or when advertising expenditure does not use up all the contributions. Are you asking your new clients about their recent job history, and checking out their answers through independent enquiry?

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