What Proactive Steps Must I Take to Identify PEPs?
· Some companies have asked customers to selfidentify as PEPs as part of the standard accountopening procedure, while others have relied on commercial PEP databases to do the due diligence (though the first method relies on the person telling the truth or even knowing that they are a PEP). Whichever method is used, the important thing is to ensure that PEP policy is always followed.