Politically exposed persons and high-risk factors

A politically exposed person (PEP) is someone who holds, or has held, a prominent public function, a government minister, senior judge, senior military officer, or a close family member or known close associate of such a person. PEP status doesn't mean someone is doing anything wrong, but the position itself creates a higher risk of bribery or corruption, so it requires enhanced due diligence.

Other high-risk factors

• Customers or transactions connected to jurisdictions with weak anti-money laundering controls.
• Complex or opaque ownership structures with no clear commercial rationale.
• Businesses that are heavily cash-based, where volumes are hard to independently verify.

None of these factors alone proves wrongdoing. They're indicators that justify a closer look, not an automatic conclusion.