Politically Exposed Persons (PEPs) in Nigeria

How to Identify a PEP in KYC?
Who is a PEP in Nigeria?
A Politically Exposed Person (PEP) in Nigeria refers to someone who holds or has held a significant public position. This group includes senior government officials, military leaders, high-ranking political party members, and their family members or close associates. Due to their influential positions, PEPs are considered at higher risk for activities like bribery, corruption, and money laundering.

Are There Official Lists of PEPs?
There isn’t a single official list of PEPs accepted everywhere. Instead, various organizations, such as banks and compliance firms, create their own lists based on guidelines from both international and local regulatory bodies. In Nigeria, the Nigerian Financial Intelligence Unit (NFIU) provides advice on identifying PEPs as part of its anti-money laundering (AML) and counter-financing terrorism (CFT) efforts.

What is PEP Identification?
PEP identification involves recognizing and confirming whether someone is a PEP. This process includes collecting information about the individual’s public office status, family ties, and close associates. Financial institutions then use this information to apply more stringent due diligence measures compared to standard procedures.

How to Identify a PEP in KYC?
Identifying a PEP during Know Your Customer (KYC) procedures includes:
Collecting Detailed Information: Gathering comprehensive data on the customer’s identity, such as their employment history and political connections.
Screening Against PEP Databases: Using software to check customers against existing PEP lists.
Ongoing Monitoring: Keeping an eye on transactions and any changes in the customer’s status to spot new PEP-related risks.

Who Qualifies as a PEP?
Typically, a PEP includes individuals who:
Hold or have held a senior government position.
Are senior executives of state-owned companies.
Hold high-ranking positions in international organizations.
Are close family members or associates of such individuals.

How to Check if a Person is a PEP?
To determine if someone is a PEP, organizations can:
Use PEP Screening Tools: Employ compliance software that checks individuals against global PEP lists.
Consult Regulatory Guidance: Follow guidelines from regulatory bodies like the Financial Action Task Force (FATF) and local financial intelligence units.
Conduct Manual Research: Look into public records, news sources, and other publicly available information.

Examples of PEP Lists
PEP lists might include:
National government officials (e.g., ministers, senators)
Senior military officers
High-ranking political party members
Executives of state-owned enterprises
Heads of international organizations

Different Types of PEPs
PEPs can be classified into:
Domestic PEPs: Those holding significant public positions within their own country.
Foreign PEPs: Officials from other countries.
International Organization PEPs: Individuals in senior roles within international organizations like the UN or World Bank.

Duration of PEP Status
A person remains a PEP while holding a prominent public position and for a certain period after leaving office. The duration varies by jurisdiction, but the FATF recommends continued monitoring for at least 12-18 months after their tenure ends.

How Probe Compliance can help in PEP Identification
Probe Compliance provides thorough solutions for identifying and managing PEP risks. By using advanced PEP screening tools, real-time monitoring, and expert regulatory advice, Probe Compliance helps organizations effectively mitigate the risks associated with PEPs. Their services streamline compliance processes, enhance due diligence, and support adherence to regulations, helping businesses maintain integrity and avoid potential issues related to politically exposed individuals.
 

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