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The "politically exposed persons" (PEP)

When entering into a business relationship with a politically exposed person (PEP), the real estate agent must:

  1. identify the customer and the beneficial owner;

  2. assess and understand the purpose and intended nature of the relationship;

  3. apply enhanced due diligence to the relationship;

  4. have in place appropriate risk management systems;

  5. obtain senior management approval for establishing or continuing business relationships with the PEP;

  6. take adequate measures to establish the source of wealth and source of funds that are involved in business relationships or transactions;

  7. conduct enhanced, ongoing monitoring of the business relationship.

What is a PEP ?

By "PEP", we mean:

1. the natural persons who are or who have been entrusted with a prominent public function, in particular:

a) heads of State, heads of government, ministers and deputy or assistant ministers;

b) members of parliament or of similar legislative bodies;

c) members of supreme courts, of constitutional courts or of other high-level judicial bodies, the decisions of which are not subject to further appeal, except in exceptional circumstances;

d) members of courts of auditors or of the boards of central banks;

e) ambassadors, chargés d'affaires and high-ranking officers in the armed forces;

f) members of the administrative, management or supervisory bodies of State-owned enterprises;

g) members of the governing bodies of political parties;

h) directors, deputy directors and members of the board or equivalent function of an international organisation;

i) natural persons exercising the functions included in the list published by the European Commission on the basis of Article 20a(3) of Directive (EU) 2015/849 of the European Parliament and of the Council of 20 May 2015 ;

2. their family members, in particular :

a) the spouse;

b) a person considered by national law to be equivalent to a spouse;

c) the children and their spouses, or persons considered by national law to be equivalent to a spouse;

d) parents;

e) brothers and sisters ; and

3. all persons known to be close associates, in particular :

a) any natural person who is known to have joint beneficial ownership of a legal entity or a legal arrangement together with a politically exposed person or to have any other close business relations with such a person;

b) any natural person who has sole beneficial ownership of a legal entity or a legal arrangement which is known to have been set up for the de facto benefit of the politically exposed person.

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