Clients that are family members and/or known close associates of FPEPs, although not themselves FPEPs, must be treated as though they are.
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WHO ARE FOREIGN POLITICALLY EXPOSED PERSONS?
An FPEP is an individual who holds, or has held a function in a foreign country as listed in Schedule 3B of the FICA:
- Head of state or head of a country or government
- Government minister or equivalent senior political or leader of a political party
- Member of a foreign royal family
- High-ranking member of the military
- Senior judicial official
- Senior executive of a state-owned entity
WHO ARE FAMILY MEMBERS OR KNOWN CLOSE ASSOCIATES?
The following relationships between a natural person and a Client will be regarded as an immediate family member relationship:
- Parents
- A spouse, civil partner or a life partner
- A former spouse, civil partner or a life partner
- Children and stepchildren and their spouse, civil partner or a life partner
- Siblings and their spouse, civil partner or a life partner
The following relationships between a natural person and a client will be regarded as a close associate:
- Known partners (for example; girlfriends, boyfriends, mistresses)
- Prominent members of the same political party, civil company, union
- Business partners or associates
- Any person who has sole ownership or control of an entity or arrangement set up for the sole benefit of the client