MI6 | Politically Exposed Persons | SIS

Politically Exposed Persons (PEP's)

A politically exposed person (PEP) is an individual who is or has been entrusted with a prominent public function. PEPs are higher-risk customers for financial institutions and Designated Non-Financial Businesses and Professions (DNFBPs) because they have more opportunities than ordinary citizens to acquire assets through unlawful means like embezzlement and bribe-taking and thus are more likely to launder money. That said, being a PEP does not in itself equate to being a criminal or suggest a link to abuse of the financial system.

 

After determining that a customer is a PEP, financial institutions and DNFBPs in most jurisdictions must apply additional AML/CFT measures to the business relationship. They are also responsible for conducting ongoing due diligence specifically tailored to the client’s PEP status. These requirements are preventive in nature and should not be interpreted as meaning that all PEPs are involved in criminal activity.

 

The term “politically exposed person” emerged in the late 1990s in the wake of the Abacha affair, a money laundering scandal in Nigeria which galvanised global efforts to prevent abuse of the financial system by political figures. A similar term, often used interchangeably with PEP, is “Senior Foreign Political Figure”. Although there is no universal definition of who classes as a PEP, most countries base their definitions on the guidelines created by the Financial Action Task Force (FATF). The FATF defines a PEP as:

  • a current or former senior official in the executive, legislative, administrative, military, or judicial branch of a government (elected or not)

  • a senior official of a major political party

  • a senior executive of a government owned commercial enterprise, being a corporation, business or other entity formed by or for the benefit of any such individual

  • an immediate family member of such individual; meaning spouse, parents, siblings, children, and spouse’s parents or siblings

  • any individual publicly known (or actually known by the relevant financial institution) to be a close personal or professional associate.

Different types of PEP are usually regarded as presenting different levels of risk. The below categorisations are not intended to be absolute, but might prove useful in thinking about which PEPs require the most careful due diligence work.

HIGH RISK - LEVEL ONE PEP

  • Heads of state and government

  • Members of government

  • Members of Parliament

  • Heads of military, judiciary, law enforcement

  • Top officials of political parties

MEDIUM RISK - LEVEL TWO PEPs

  • Senior officials of the military, judiciary and law enforcement agencies.

  • Senior officials of other state agencies.

  • Senior members of religious groups.

  • Ambassadors, consuls, high commissioners

MEDIUM RISK - LEVEL THREE PEPs

  • Senior management of a board of directors and state owned enterprises.

LOW RISK - LEVEL FOUR PEPs

  • Mayors, governors and members of local and city assemblies.

  • Senior officials of international organisations

The Remora Principle
The CEO at Patrium Intelligence (one of our appointed Private Intelligence Agencies) recently coined the term "The Remora Principle" and how it describes a method of operating within Secret Intelligence globally.  The phrase to 'operate within the shadows' is often used, however the Remora Principle outlines in specific detail how effective intelligence gathering is achieved by not only staying within the shadows of a larger, more distracting element, but to move with it.  It provides key steps Intelligence Agents should take to ensure effective information gathering and reporting to officers, and focuses more on modern technological advancement.  By following the steps outlined within the Remora Principle, one is able to then tailor specific actions that are applicable to individual operations.
Q: Can we induce an event which leads to a material and significant change in a person’s ability or behaviour which would be useful to an organisation such as MI6?

Straps yourselves in for a little bit of a wild ride, so if extreme sports of the academic or indeed philosophical kind are not your thing, then please unbuckle now and leave the park. The four terms used in the title would appear at first glance to be connected, but for the purposes of this article, are not.  There is a distinct, and key difference in that they refer to a journey of sorts.  The journey of the mind and neural functionality that eventually leads to a change which has been caused by an ‘event’. Each term describes a condition.  A condition of the brain at a point in the journey. 

Where did my Taxi Driver and my money go?”

 

Whenever there is a radical and rapid development in Technology, the voices of those who fear the human effects of such developments sing loud.  Of course, debate is ultimately a healthy proposition when conducted in the correct manner i.e a respectful exchange of ideas, evidence and facts to determine the truth or at least the likelihood of why ‘something’ happens.  The problem is that as we venture further up the emotional curve and hit the raw nerve of public consciousness, a healthy debate, absent of extreme views, is less and less likely.   This is quite possibly the stage we are at now when it comes to the vast changes of technological development at exponential rates of growth.  If one then throws into the mix a subject such as Artificial Intelligence, which has been the subject of many a doomsday prophecy, especially in the fictional world, then the prediction of likely effects  becomes distorted.  There are a vast number of capillaceous issues branching out from each topic within AI and on a scale which precludes us from analysis in this article due to time.  However, there are rarely more topics as emotive as a person's job and their ability to generate income in order to survive...so will driverless cars render the taxi driver extinct and will money even be necessary in any form? Read More. 13.08.19

Dark Web

An Opportunity or Threat?

Perceived wisdom suggests the Dark Web is synonymous with illegal activities involving weapons, drugs and paedophiia.  The assumption has been that if you use it, then you have something sinister to hide.  To be fair, closure of drug giants like "Silk Road" did nothing to change those perceptions.  However, in the big brother world of surveillance, the search for privacy is demanded by the majority and will be found in some way or another.  Furthermore, in a society where people are being increasingly attracted to the fringes of life,  the shift to increasing usage of the Dark Web is a given.  That does not mean it is wrong however, and as we often witness, it is people from the 'fringes' who sometimes operate outside of social norms, who provide the greatest sources of innovation.  We firmly believe the dark web will undergo an upgrade of sorts and although usual, non-secured browser based sites will attract some attention, their days are numbered.  The really exciting proposition is to predict Dark Web 2.0, 3.0 and so on. Rather ironically, but understandably, it is the law enforcement and intelligence agencies who are spending more and more resources on hiding within the shadows of the Dark Web.  It has been the most effective way so far.  However, as it grows, it will it continue to be the safe haven of the criminal or will some form of regulation (such as was with the legalisation of drugs etc), prevent the extreme offenders?  Take the example of Silk Road. It is not only possible, it is probable.  Whether you are in favour of legalisation generally or not,  in many cases it is a safer option.  Many of the sites that offered Marijuana were ran as slick commercial organisations where consumer satisfaction was paramount.  The product was therefore of superior quality (apparently) and it was offered within the relative safety of the internet and not some dark street corner.  Maybe that one is for the liberals out there.  For our purposes however, it shows that the deep dark web does actually have a USP which can be monetized, namely privacy.  Looking further head therefore, the real drug that will sell well in our 'Orwellian' future, is anonymity.  That will undoubtedly be the most precious of commodities.

 

As it stands now however, people and the societies they live in tend to display tendencies to self-regulate and yes, whilst there is always potential for abuse, the masses will (or should) drive the market to some degree of parity.  There are certainly huge opportunities around the corner.  A secured 'blockchain'esque' physical depository for parcel delivery is bound to happen on a large scale and accompany the growth of the Dark Web.  That is because the only chink in its armour at the moment is complete anonymity with delivery of items. Imagine a secure facility where parcels (aka Data) entering from one side, is subjected to 'scrambling' (aka 'Encryption') and leave the other side to be collected by a seemingly unconnected party (aka 'You').  Now multiply that across every City in the UK.  You then have what one can REALLY call an encrypted, secure, supply chain that would be undetectable to all agencies and, most importantly, legal  Read More.

Innovation, technology and the military are inextricably linked, and throughout history whenever there is a technological breakthrough, one of the first beneficiaries is invariably the military.  Whether it is recent developments such as GPS, or much later, Galileo selling telescopes to Italian monasteries to see enemy ships approaching, the human desire to conquer or defend is paramount. With the 'genie' firmly out of the bottle, Artifical Intelligence will become a 'game changer' in the Military world as for many, the upsides are simply too strong to worry about potentially disastrous consequences.  Here we take a look at the detail and the precise areas of growth just around the corner.Read More

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