Isle of Man Financial Services legislation requires that Manx Financial Institutions undertake ‘enhanced’ due diligence on ‘Politically Exposed Persons’ (PEPs). The definition varies from jurisdiction to jurisdiction. There is quite a useful explanation here on Wikipedia.


Sometimes it is assumed that all people in the public eye – such as celebrities and other well known persons –  are PEPS but this is incorrect. The definition is quite narrowly drawn and is restricted to those with political influence.


In the Isle of Man the definition is contained within the Section 2. Interpretation and revocation of the  Proceeds of Crime Act 2008 – Proceeds of Crime (Money Laundering) Code 2010 – the relevant section reads as follows:


“politically exposed person” means any of the following resident in a country or territory outside the Island —
(a) a natural person who is or has been entrusted with prominent public functions, including —
(i) a head of state, head of government, minister or deputy or assistant minister;
(ii) a senior government official;
(iii) a member of parliament;
(iv) a senior politician;
(v) an important political party official;
(vi) a senior judicial official;
(vii) a member of a court of auditors or the board of a central bank;
(viii) an ambassador, chargé d’affaires or other high?ranking officer in a diplomatic service;
(ix) a high?ranking officer in an armed force;
(x) a senior member of an administrative, management or supervisory body of a State?owned enterprise;
(xi) a senior official of an international entity or organisation;
(xii) an honorary consul;


(b) any of the following family members of a person mentioned insub?paragraph (a) —

(i) a spouse;

(ii) a partner considered by national law as equivalent to a spouse;

(iii) a child or the spouse or partner of a child;
(iv) a brother or sister (including a half?brother or half?sister);
(v) a parent;
(vi) a parent?in?law;
(vii) a grandparent; and
(viii) a grandchild;

(c) any close associate of a person mentioned in sub?paragraph (a), including —
(i) any natural person who is known to have joint beneficial ownership of a legal entity or legal arrangement, or any other close business relations, with such a person;
(ii) any natural person who has sole beneficial ownership of a legal entity or legal arrangement which is known to have been set up for the benefit of such a person;
(iii) any natural person who is known to be beneficiary of a legal arrangement of which such a person is a beneficial owner or beneficiary;
(iv) any natural person who is known to be in a position to conduct substantial financial transactions on behalf of such a person;


It is interesting to note that residents of the Isle of Man cannot be PEPs under Manx law. I suppose that technically means if Robert Mugabe’s family moved to the Isle of Man that would not be PEPs under our definition…strange !


photo credit: Walwyn via photo pin cc


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