On January 22, 2025, Resolution No. 00199-2025 was published regarding the functions and positions of Politically Exposed Persons (PEPs) for the prevention of money laundering (ML/FT).
Main Changes
Update of the PEP Definition
The general definition is maintained and it is emphasized that PEPs are subject to the application of the enhanced due diligence regime in customer knowledge.
Modification of the List of Positions and Functions:
Section h) of paragraph 2 of the Annex is repealed, excluding employees of state-owned companies and Municipal Savings and Credit Funds (CMAC) as PEPs, due to the fact that they are not included in the public function and the private nature of these.
The exclusion of employees of state-owned companies and CMACs from the PEP regime seeks to improve the accuracy and effectiveness of risk identification, allowing regulated entities to focus their efforts on those whose public and financial exposure poses the greatest ML/TF risks.
For more information on how to adapt your SPLAFT to this regulation or for technical assistance with implementation, you can contact us here.
Do you have any further questions or concerns? Don't hesitate to contact us. a compliance@cpb-abogados.com.pe
