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  4. Guidance on the treatment of politically exposed persons (PEPs) under the Money Laundering Regulations 2017

Guidance on the treatment of politically exposed persons (PEPs) under the Money Laundering Regulations 2017

Last updated: 18 Apr 2017

Consulting body:
Financial Conduct Authority
Period of consultation:
Runs from 15 March 2017 to 18 April 2017
CML action:
Response submitted

The Financial Conduct Authority have published draft guidance on politically exposed persons (PEPs) to firms who are supervised by them under the Money Laundering regulations, as per the requirements under s333U of the Financial Services and Markets Act.

Our response to the consultation on the fourth money laundering directive sought additional clarification for firms on the treatment of PEPs; so this guidance is welcome, and we will respond on points of relevance to mortgage lenders.

CML response

We welcome and support the guidance document, which should aid lenders in carrying out their anti-money laundering (AML) obligations.

We believe the main risks have been identified in the guidance; however some further clarification and examples would be of benefit.

For example, it would be helpful to include case studies, especially for ‘greyer’ circumstances; and some additional guidance on particular aspects relating to foreign PEPs, such as their usual employment and residency status.

The full CML response can be downloaded below.


  1. CML response to FCA guidance on PEPS (PDF 118KB)