As per FCA’s Guideline „FG17/6: The treatment of politically exposed persons for anti-money laundering purposes“, the FCA will assess how „regulated firms are complying with their legal and regulatory obligations regarding the risk management and treatment of Politically Exposed Persons (PEPs)“. In June 2023, a letter from Baronness Penn has been sent to FCA’s Chief Executive Officer, Nikhil Rathi emphasising the importance of engaging PEP’s in the assessment because it is crucial to understand the perspective of the affected person directly.
The FCA has confirmed that it has received various information from PEP’s on their opinion and experiences regarding this topic. However, the FCA is calling for more PEP’s to engage in improving the assessment process and therefore is asking for feedback on cases when PEP’s engagement with firms has been negative in relation to the following:
– nature and reason(s) regarding complaint or negative experience, when did this occur and which Firm(s) was involved?
– what products / services were involved
– who was affected (PEP, the family)
– consequences of the negative approach
– form and method of communication between the firm and PEP
– an example of a positive interaction
Written feedback should be submitted before the end of September, ideally.