DIA Targeted Compliance Assessments – PEP thematic
DIA Targeted Compliance Assessments – PEP thematic
22/04/2021
The DIA recently undertook a review of policies, procedures and controls relating to politically exposed persons. 50 reporting entities were targeted, comprising 34 lawyers and 16 real estate agents.
Key issues identified
No policy in AML/CFT Programme to conduct PEP checks on each customer and beneficial owner
No policy in the AML/CFT Programme which required Senior Manager approval before continuing a business relationship with a PEP
No procedure in the AML/CFT Programme which outlined how to conduct a PEP check
No policy or procedure in AML/CFT Programme to keep a record of each PEP check undertaken
No NZ definition in the AML/CFT Programme of what a PEP is and what persons are included
No control in the AML/CFT Programme to ensure that PEP checks had been completed
Summary of Findings (graphs produced by 4S AML based on information published by the DIA)
