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Politically exposed persons
Pursuant to the provisions of Sec. 4, paragraph 5 of the AML Act, a politically exposed person (PEP) is:
a) a natural person who is or has been entrusted with a public function of nation-wide or regional importance, such as in particular head of state, head of government, head of a central government body and the head's deputy (deputy minister, secretary of state), member of parliament, member of a governing body of political parties, leading official of a regional government, member of the supreme court, constitutional court or of other high-level judicial bodies, the decisions of which are not subject to further appeal except in exceptional circumstances, member of the central bank's banking board, high-ranking officer in the armed forces or corps, member or representative of a member, in the case of a legal entity, of the statutory body of a state-controlled commercial corporation, ambassador or head of diplomatic mission, and/or natural person who is or has been performing a similar office in another state, European Union authority and/or international organization,
b) a natural person who is
- a person related to a person referred to in point a),
- joint or beneficial owner of the same legal entity or trust as a person specified under point a), or who is known to the bank to be in any other close business relation with a person specified under point a), or
- beneficial owner of a legal entity or trust which are known to the bank to have been set up for the benefit of a person specified under point a).
The website of the Financial Analytical Office displays Methodological Guideline 7 including the List of National Prominent Public Functions and Consolidated List of Prominent Public Functions in the EU and International Organizations establishing the PEP status.
Thus, for example, the mayor of a municipality with extended competence, an ambassador or the wife of a senator are politically exposed persons. The mere performance of the function of, for example, an ordinary member of a political party or a mayor of a municipality without extended competence does not establish the PEP status.
The status of a politically exposed person remains valid for at least 12 months from the moment the person ceases to perform the function establishing such status. The same conditions apply to the application of the status of a “derived” politically exposed person – see paragraph b) of the above definition of a Politically Exposed Person.
The client undertook to inform the bank in the course of the business relationship if he or she performs or has performed a prominent public function of national or regional importance in the Czech Republic or another country, in the bodies of the European Union or in an international organization, or is in a close relationship with such a person. The obligation to inform also applies to changes in the client’s status of a politically exposed person.
General Business Conditions - Chapter 2.4. Politically Exposed Person
Raiffeisenbank a.s. performs client due diligence to eliminate the risks of money laundering and terrorist financing to the greatest possible extent. Client due diligence is often known as "Know Your Customer". At the bank's request, every client is obliged to provide the information necessary for the due diligence and to submit the relevant documents. If the client fails to provide such cooperation or if the client due diligence cannot be carried out for any other reason, the bank must proceed in accordance with applicable laws.
The bank ascertains and evaluates information on the purpose and nature of the transaction or business relationship, the nature of business activities, information on the identification and verification of the client's beneficial ownership and identification of the client's management and ownership structure, and information on the origin of assets of a politically exposed person or on the application of international sanctions to the client. In accordance with Sec. 9a of Act No. 253/2008 Coll., the bank carries out enhanced identification and due diligence of clients with a high-risk third country as their country of origin, all at any time during the establishment or existence of the business relationship. The list of high-risk countries is determined on the basis of Commission Regulation (EU) 2016/1675 and the FATF list of high-risk countries. From the bank's perspective, AML (Anti Money Laundering) rules must be adhered to. These are anti-money laundering measures that are also intended to combat the financing of terrorism (CFT).
The bank treats all client data and submitted information in accordance with the principles of banking secrecy.