Greenberg, Theodore S.; Gray, Larissa; Schantz, Delphine; Gardner, Carolin; Latham, Michael
Description:
The paper is focused on the banking
sector, not on other financial and nonfinancial sectors
vulnerable to the laundering of corrupt funds. These other
sectors may find the recommendations and good practices
provided in this paper relevant, but should analyze the
findings of this paper in light of their particular
circumstances and specific features. The paper includes a
number of practical tools to help guide banks, regulators,
and other public authorities. The paper is organized into
four major parts: the remainder of this part (part one) sets
out some of the main observations and trends in politically
exposed person (PEPs) compliance and an analysis of the
principal reasons for poor compliance and overall
ineffectiveness of systems to detect and monitor PEPs. Part
two focuses on the implementation of PEP measures by
regulatory authorities and banks. Part three reviews the
roles of the public authorities that are primarily involved
in preventing abuse by corrupt PEPs. These authorities
include the regulatory authority, which is responsible for
providing guidance to banks and enforcing compliance, as
well as the financial intelligence unit (FIU), which has a
role in the context of suspicious transaction reports (STRs)
on PEPs. Finally, part four considers some of the
cross-cutting issues national cooperation, training, and
resources that must be addressed by all stakeholders.