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Checklist: opening a relationship with a politically exposed person

  • Identify the politically exposed person status of the client, of the beneficial owner and of their close associates and family members, using databases and supplementary research.
  • Clarify in depth the origin of the wealth and of the funds, distinguishing income from public office, private activities and inheritances, and obtaining supporting documents.
  • Analyse the country in which the office is held, its level of corruption and the existence of proceedings or sanctions targeting the client or those close to the client.
  • Submit the opening of the relationship to the approval of senior management and document the decision and its reasons.
  • Define enhanced monitoring of transactions and a periodic review at short intervals.
  • Verify the tax compliance of the assets in the country of residence and the absence of applicable sanctions.
  • Provide for the conditions under which the relationship would be terminated and the assets reported or frozen.

For general information only. This article does not constitute legal or tax advice, does not replace advice on an individual case and creates no lawyer-client relationship. It reflects the legal position as of September 2025.

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