- Ülkede para yok ki, karapara nasıl olsun diyen devlet adamları (politikacılar) ve üst düzey (devlet) yöneticileri,
- Soru sormayan, soru sormaktan kaçınan bankacılar,
- Paranın karası beyazı olmaz diyen bankacılar ve devlet adamları
Siyasi Nüfuz Sahibi Kişiler (PEPs) olarak tanımlanır.
PEPs: Unsolved Issues and Suggestions on PEPs:
1. Approach: Avoid Setting Limits on the Time- a PEP Remains a PEP. According to UNCAC and FATF: once a PEP always a PEP.
2. Issue: Problems with time limits of the PEPs,
3. Approach: Consider on case-by-case basis using risk-based approach,
4. Issue: PEPs are an asymmetric risk – no one single tool will solve problem,
5. Issue: National List of PEPs (in TRNC ?).
6. PEPs Management Issue: ‘”An enterprise-wide compliance risk-management program should be dynamic and proactive. It should assess evolving risks when new business lines or activities are added, when existing activities and processes are altered, or when there are regulatory change.The process should include an assessment of how those changes may affect the level and nature of risk exposures, and whether mitigating controls are effective in limiting exposures to targeted levels. To avoid having a program that operates on autopilot, an organization must continuously reassess its risks and controls and communicate with all employees who are part of the compliance process. If compliance is seen as a one-off project, an organization faces the risk that its compliance program will not keep up with the changes in its services or customer mix” -Governor Susan Schmidt Bies (former)- Board of Governors of the Federal Reserve System.
7. Issue: Periodic Review of PEP Customers. Review of the big picture on risk-based approach, at least yearly.
8. Private Banking Phenomena: Special rules apply to Senior Foreign Political Figures (SFPF-PEPs)
9. Enforcement Issue: Use of sanctions-PEPs component in on-site inspections ? (TRNC)
10. Good Practice: PEPs Committee
11. Level the playing field: Banks and other players should take actions on PEPs and should go beyond the international standards
12. Issue-PEPs: Local PEPs are risky as foreign PEPs- dynamic and proactive approach and Continous Enhanced.Standards (National and international) are not sufficient.
13. Final Words (MUST): Avoid having a program (PEPs) that operates on autopilot !!! Dynamic and proactive approach for managing risk(s)- PEPs.- is the MUST !