Jersey, ONCE A PEP, ALWAYS A PEP
I am regularly asked about the once a PEP always PEP status in Jersey and whether it is a voluntary matter
My answer is:-
Unlike the UK, the Jersey law does not close out [sunset provision] for when a person ceases to be entrusted with that public function.
The UK stipulates the following, that as you can see, has sunset clauses for when a PEP status stops for AML purposes, as noted below
- Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017
- Regulation 35(9)(a) and (b) provides that a person who is a PEP should continue to be treated as a PEP
- For a period of at least 12 months after the date on which that person ceased to be entrusted with that public function; or
- For such longer period as the relevant person considers appropriate to address risks of money laundering or terrorist financing in relation to that person. And
- For lower-risk situations, it will not normally be necessary to continue treating someone as a PEP for longer than 12 months after leaving office.
So its ONCE A PEP, ALWAYS A PEP
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