Politically Exposed Persons (PEP’s)

A new “Venture Capital Control,” under the guise of a Sanctions regime is, perhaps, an easy way of explaining the ills, a cover of or for the invasion.

by Victor Cherubim

For those readers who think I am writing about the Government in Sri Lanka, you are mistaken. Of course, there has been a plethora of information of activity over the last month about our protest marches, our President, our Prime Minister and of the dynasty, let me say, it is uncouth, if not ugly for a Sri Lankan to say what a hideous situation we the people of our land, have placed ourselves in, and laid ourselves bare, due to our foibles.

However, we are gobsmacked to hear the news of Ms.Angela Rayner, M.P, and the Deputy Labour Party Leader in UK, that she had uncrossed her legs in the House of Commons to distract Boris Johnson at Prime Ministers’ Question time in January this year (2022), when she was acting for the Leader of the Opposition, Sir KierStarmer. She had joked about her “tactic” during a late night conversation on the Commons terrace with three other fellow MP’s who were part of the group, one of them, a woman M.P. 

In her own words, she is supposed to have stated: “I wasn’t aware I did it. But apparently like there was, this whole meme about how my dress was like a bit revealing. But, I didn’t think it was, think it was. It was perfectly suitable Karen Millen (dress) – in the sale”, (laughs).

This whole episode has ignited public comment among the Brits, reeling over the “Cost of Living without money,” ever since the “Mail on Sunday” (MoS) exposed it, in its edition last weekend (24 April, 2022).

The Paper’s Editor, David Dillion has declined a request for a meeting with the House of Commons (HoC) Speaker, Sir Lindsay Hoyle, who now seems to have second thoughts about his Commons sermons about banning the MoS Editor, David Dillon and his Political Editor, from entry to the Commons.

David Dillion has tendered a letter to the Speaker stating: “MoS deplores sexism and misogyny in all its forms but journalists must be free to report what they are told by MP’s about conversations which take place in the Commons, however unpalatable some may find them.”

“Britain rightly prides itself on its free press. That freedom will not last if journalists have to take instruction from officials of the House of Commons, however, august they may be, on what they can and cannot report.”

“Crossing and uncrossing legs”

My readers will note that it has drawn comparisons with the “Basic Instinct” star actor, Sharon Stone, but the million dollar question in the minds of many: “Did it in any way distract Boris Johnson, who is a great debater at Oxford Union in his Uni days?”

The comparison of unease between Sri Lanka and UK ends there, with those in Sri Lanka haven’t got the money to spend, whilst in the UK, people have the money, but areafraid to spend, due perhaps, to scare mongering. No doubt, the Brits are feeling the pinch with the energy price cap increasing with no other option, than toopen their cheque books, which is now a rare commodity, or “going on the never, never?”

“Sanctions, o’sanctions”

The real distraction in our minds is sanctions, very much in the public eye, beside misogyny, since Russia trespassed into Ukraine.

The international strategy of “putting pressure” on Russia and its economy has seen a continuous escalation of sanctions. 

It is the suggestion, rather the indication, that the West; UK, US, EU are bound to take further action, if not in the days, weeks or months ahead.

I refer to the onerous and ever changing situation of the containment of the war in Ukraine, with the onerous compliance challenges, envisaged.

With the speed at which sanctions are being introduced; people, individuals and businesses; and/or entities being flagged up on Lists of Global Sanctions or often referred to as Politically Exposed Persons, (PEPS) Lists.

Politically Exposed are now in the limelight. It is essential now to ensure accurate identification of newly sanctioned individuals and entities, with connections, links, or business with Russia, besides.

Any business, countries or individuals who have relied on old fashioned paper checks or who use electronic verification systems to update monitoring, are taking enormous risk of breaching sanctions. 

A New PEP List is being compiled, similar to the World’s Rich List. Alerts on new additions to Sanctions need to be scrutinised, to see if a Client, or a Company or a PEP, has been successfully screened. 

This is all the more necessary under the new UK “Economic Crime (Transparency and Enforcement) Act2022, to see if breaches of financial sanctions are designated a strict liability civil offence. This is punishable by fines up to £1 million. 

Thus anyone with assets frozen by sanctions hasto be duly scrutinised. The law now lays down that failure to conduct proper “Sanctions Due Diligence” cannot be dismissed as an unfortunate oversight. 

“Freeing up Capital”

Freeing up Capital is the new Risk Assessment for Politically Exposed Persons. The sheer scale of the work involved in effective screening is compounded by the over 1million worldwide sanctions and Politically Exposed Persons. The potential implications this UK Law has imposed is daunting, to say the least.

Was it all planned in advance of the Russian invasion of Ukraine?

Sanctions have not only targeted Russia, but all the more for trafficking in drugs, firearms and money laundering. What it literally means is that money held in banks are being frozen, access to property owned is restricted, free movement and travel is under scrutiny. Ordinary peoples’ Credit and Debit Cards are being blocked, as penalty.

Curtailment of freedom, as we have come to know over decades is being exposed on the pretext of a sanctions regime. How far this “economic crime” is an infringement of personal liberty is under scrutiny?

Reputation Management is the new name game. A new “Venture Capital Control,” under the guise of a Sanctions regime is,perhaps, an easy way of explaining the ills, a cover of or for the invasion.

“Whilst some will claim this Economic Crime Act 2022, does not go far enough it is clearly an important development. The momentum set by this Act is clear – standards of diligence in overseas wealth entering the UK can no longer operate in silo to that of the ordinary UK citizen. Authorities now have significant powers and offenders face both fines and custodial sentences.

London has enjoyed an unprecedented position in the eyes of the ultra-wealthy – an infrastructure that goes far beyond the property purchases preoccupied by the Act. Luxury goods suppliers, money managers and services providers will undoubtedly be assessing their own governance and controls to ensure they are aligned to both the spirit of the Act, and a growing public sentiment against any perception of a ‘soft’ approach towards dubious funds entering the UK”.