Jersey, ONCE A PEP, ALWAYS A PEP
30/03/2022
I am regularly asked about the once a PEP always PEP status in Jersey and whether it is a voluntary matter
My answer is:-
Unlike the UK, the Jersey law does not close out [sunset provision] for when a person ceases to be entrusted with that public function.
The UK stipulates the following, that as you can see, has sunset clauses for when a PEP status stops for AML purposes, as noted below
- Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017
- Regulation 35(9)(a) and (b) provides that a person who is a PEP should continue to be treated as a PEP
- For a period of at least 12 months after the date on which that person ceased to be entrusted with that public function; or
- For such longer period as the relevant person considers appropriate to address risks of money laundering or terrorist financing in relation to that person. And
- For lower-risk situations, it will not normally be necessary to continue treating someone as a PEP for longer than 12 months after leaving office.
So its ONCE A PEP, ALWAYS A PEP
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As well as owning and publishing Comsure's copyrighted works, Comsure wishes to use the copyright-protected works of others. To do so, Comsure is applying for exemptions in the UK copyright law. There are certain very specific situations where Comsure is permitted to do so without seeking permission from the owner. These exemptions are in the copyright sections of the Copyright, Designs and Patents Act 1988 (as amended)[www.gov.UK/government/publications/copyright-acts-and-related-laws]. Many situations allow for Comsure to apply for exemptions. These include 1] Non-commercial research and private study, 2] Criticism, review and reporting of current events, 3] the copying of works in any medium as long as the use is to illustrate a point. 4] no posting is for commercial purposes [payment]. (for a full list of exemptions, please read here www.gov.uk/guidance/exceptions-to-copyright]. Concerning the exceptions, Comsure will acknowledge the work of the source author by providing a link to the source material. Comsure claims no ownership of non-Comsure content. The non-Comsure articles posted on the Comsure website are deemed important, relevant, and newsworthy to a Comsure audience (e.g. regulated financial services and professional firms [DNFSBs]). Comsure does not wish to take any credit for the publication, and the publication can be read in full in its original form if you click the articles link that always accompanies the news item. Also, Comsure does not seek any payment for highlighting these important articles. If you want any article removed, Comsure will automatically do so on a reasonable request if you email info@comsuregroup.com.