Grant Saw policy on Politically Exposed Persons

In order to tackle corruption at international and national level, the Money Laundering Regulations 2017 require Grant Saw Solicitors LLP to have in place appropriate systems to identify and manage the perceived enhanced risks presented if we act for Politically Exposed Persons (“PEPs”).  

 

It is a condition of your retainer with the firm that you must tell us if you fall into any of the following categories.  If you do fall into one or more of these categories then this does not mean that we cannot act for you, but only that we need to consider and then deal appropriately with any enhanced risks posed by the transaction which we identify. 

 

The different categories are:-

 

  • Heads of State
  • Heads of Government
  • Ministers, Deputy or Assistant Ministers
  • Members of Parliament or similar legislative bodies
  • Members of governing bodies of political parties
  • Members of Supreme Courts, of Constitutional Courts, or any judicial body whose decisions are not subject to further appeal, except in exceptional circumstances.
  • Members of courts of auditors or of the boards of central banks
  • Ambassadors, charges d’affaires and high-ranking officers in the armed forces
  • Members of the administrative, management or supervisory bodies of State-owned enterprises
  • Directors, deputy directors and members of the board or equivalent function or an international organisation
  • Family members of a PEP – spouse, civil partner, children, their spouses or partners and parents
  • Known close associates of a PEP – persons with whom joint beneficial legal ownership of a legal entity or legal arrangement is held, with whom there are close business relationships, or who is a sole beneficial owner of a legal entity or arrangement set up by the primary PEP.

 

We shall assume, unless you advise us to the contrary in writing, that you do not fall into any of the above categories.

 

Grant Saw Solicitors LLP

June 2017

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