Financial institutions should have effective Bank Secrecy Act/Anti-Money Laundering (“BSA/AML”) and Office of Foreign Assets Control (“OFAC”) policies and procedures to manage the risks associated with senior political figures, otherwise known as “politically exposed persons (PEPs).” Under the Federal Financial Institutions Examination Council’s BSA/AML Examination Manual (“FFIEC Manual”), PEPs include: Any corporation, business, or other […]
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