A Guide to Anti-Money Laundering for Crypto Firms
5MLD requires EU member states to compile and publicly release a functional PEP list – made up of prominent politically exposed public functions. This requirement extends to accredited international organizations, and the EU will also release an EU-level version of the list.Functional PEP lists are rare and so can need a little explaining. The list created by member states for 5MLD will feature the name of positions that are considered politically exposed but will not name the person fulfilling the function, which periodically changes. These lists are designed to make it easier for smaller compliance teams, or those with lower volumes of customers, to identify the PEPs that they should be screening against and monitoring for ongoing changes to risk. Keeping a list of people filling these functions up to date may involve significant administrative effort as Joanna Jenkins, Chief Compliance Officer at Railsbank said “data discrepancies could cause issues” – meaning companies should take careful steps to ensure a sufficient level of compliance.
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Originally published September 6, 2018, updated May 5, 2022
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