Decisions on fees and charges are a commercial matter for firms. However, the Financial Conduct Authority (FCA) requires firms to treat their customers fairly, and has broad and robust powers to enforce breaches of its rules.
The latest Money Laundering Regulations are clear that firms must apply a risk-sensitive approach to identifying politically exposed persons (PEPs) and then applying enhanced due diligence (EDD) measures appropriately. This extends to assessing the circumstances in which the beneficial owner of a company is a PEP.
The FCA has published guidance on how firms should identify and apply EDD measures to PEPs. This makes clear that UK PEPs should be treated as a low risk of money laundering, unless an FCA-regulated firm assesses that other risk factors not linked to their position as a PEP mean they pose a higher risk.