A Politically Exposed Person ("PEP") is a person entrusted with a prominent public function. Family members and known close associates of PEPs are also subject to additional AML requirements.
PEP status does not prevent Keystone from acting. PEPs are not inherently dishonest and the existence of a PEP relationship should not be treated as evidence of criminality. However, individuals who hold prominent public functions may present increased corruption, bribery, sanctions, reputational or abuse-of-office risks. For this reason, the Money Laundering Regulations require additional measures to be applied where a PEP relationship exists.
The Firm's detailed requirements are set out in the PEP Policy. This section explains the practical responsibilities of the responsible lawyer.