Question 1

What is a Politically Exposed Person (PEP)?

Accepted Answer

A PEP is a person who holds or has held a prominent public function, such as heads of state, legislators, senior judges, ambassadors, high-ranking military officers and executives of state-owned companies. AML/CFT regulations require enhanced due diligence for PEPs, their family members and close associates.

Question 2

What is a PEP under United States rules?

Accepted Answer

The United States has no official PEP list like the one kept by Mexico's Financial Intelligence Unit. BSA regulations use the term "senior foreign political figure" (31 CFR 1010.605) and require enhanced scrutiny of private banking accounts held by those persons, their family members and close associates. For other relationships, FinCEN and the banking regulators expect a risk-based approach.

Question 3

Why run compliance screening in the United States?

Accepted Answer

The BSA requires financial institutions to run an AML program with customer identification and monitoring; FinCEN's CDD Rule requires identifying the beneficial owner; and OFAC sanctions apply to every U.S. person under strict liability. Screening against sanctions lists, PEPs and adverse media is the evidence that those obligations were met.

Question 4

What data sources does VP 360° use?

Accepted Answer

VP 360° integrates 44 active sources in 26 countries, including Mexico's federal transparency payroll, the INAFED municipal directory, federal pensioners, national parliaments, the OFAC SDN list, UN sanctions, INTERPOL red notices and the CIA world leaders list.