My September 26, 2008 Asset Search News Roundup mentioned that public corruption crimes can involve concealing bribe payments or other illicit assets.  This is perhaps why financial institutions sometimes check lists of “Politically Exposed Persons“, (i.e. individuals holding high foreign public office, a.k.a. “PEPs”), in an anti-money laundering program.  These lists of “Politically Exposed Persons” are commercially available from World-Check’s PEP Database, WorldCompliance’s Global PEP List, etc.

The Wolfsberg Group and the Financial Action Task Force’s “6th Recommendation” consider Politically Exposed Persons to be money laundering risks.  Page 10 of the Basel Committee’s October 2001 publication “Customer due diligence for banks“, similarly describes the problem of Politically Exposed Persons hiding assets through money laundering.

Furthermore, according to an Associated Press article, (“Davos: Don’t let crisis breed more corruption”), the Annual Meeting of the World Economic Forum just warned that the global financial crisis could lead to even more public corruption.  We may therefore experience an increased risk of Politically Exposed Persons using money laundering to hide bribe payments and / or other criminal proceeds.

(Edited January 5, 2010)

Copyright 2009 Fred L. Abrams