“In any of these cases, there may be circumstances which mitigate against such a categorization including separation and estrangement, although these facts should be investigated and recorded,” the report adds.
The Wolfsberg report also defines the concept of a “close associate”, who it says will include “a PEP's widely and publicly known close business colleagues and/or personal advisors, in particular financial advisors or persons acting in a financial fiduciary capacity”.
The Indian experts point out that on July 2, the Reserve Bank of India (RBI) sent an advisory to banks on PEPs that pretty much repeats what FATF and the Wolfsberg Group said, specifically adding that “the norms may also be applied to the accounts of the family members or close relatives of PEPs”.
