NZ AML/CFT Compliance Officer study materials
NZ AML/CFT Compliance Officer study resources

The Politically Exposed Person Next Door

NZ AML/CFT Compliance Officer · Put your knowledge to work in context.

All case studies

The Politically Exposed Person Next Door

A wealth management firm is onboarding a customer who is a New Zealand resident and has lived here for 20 years. He is a retired former minister of finance of a small Pacific island nation, having left office 12 years ago. He wishes to invest NZ$1.5 million from an offshore account. His son, who is a current member of that country's parliament, is also a signatory on the investing entity. The relationship manager argues that because the customer has lived in NZ for two decades and left office long ago, he is 'no longer a PEP' and standard CDD applies. The customer has provided a passport and a rates notice. The offshore account is in a jurisdiction the firm rates as higher risk.

1. Is the customer a politically exposed person, and does the passage of time or NZ residency remove that status?

Read the worked answer

PEP status. A PEP is an individual who holds, or has held, a prominent public function - heads of state, ministers, senior officials, and similar - including former holders of such functions. The customer was a minister of finance, which is squarely within the definition. The son, as a current MP, is also a PEP.

Does time or residency remove it?

  • Residency in New Zealand does not remove PEP status. The definition attaches to the function held, not to where the person now lives.
  • Time since leaving office is a risk factor, not an automatic erasure. The firm should treat former PEPs as continuing to present higher risk for a period, and the fact that he left office 12 years ago may reduce - but does not eliminate - the risk. The firm must apply a risk-based approach and document its reasoning; it cannot simply declare him 'no longer a PEP'.
  • The son as current MP and signatory is a separate and current PEP connection that must be assessed.

Conclusion: enhanced CDD applies. Standard CDD is not sufficient.

2. What enhanced CDD measures are required, and what governance approvals and ongoing obligations apply?

Read the worked answer

Enhanced CDD:

  1. Establish source of wealth and source of funds for the NZ$1.5m with independent, reliable evidence - not just a passport and rates notice.
  2. Establish the source of the offshore funds and the reason for the offshore account, given the higher-risk jurisdiction.
  3. Identify and verify all beneficial owners of the investing entity, including the son and any other controllers.
  4. Adverse media and sanctions screening on both the former minister and the current MP, covering their public functions and any allegations.
  5. Understand the purpose and intended nature of the relationship.

Governance:

  • Senior management approval is required before establishing (or continuing) a relationship with a PEP.
  • Document the risk assessment and the approval decision.

Ongoing obligations:

  • Enhanced ongoing monitoring of the relationship and transactions.
  • Periodic review of PEP status and risk rating.
  • If any activity appears suspicious, a SAR should be considered, with the usual tipping-off prohibition.

The relationship manager's 'he's been here 20 years' argument is a risk-factor observation, not a basis to downgrade to standard CDD.