Compliance Memo

Compliance Memorandum 2017-02; AML Update

For more information, contact:

Compliance Team

Date Issued:

July 6, 2017

Recent amendments to AML regulations have expanded the documenting requirements for a Politically Exposed Foreign Person. As part of your requirement to identify foreign politically exposed persons, you must now identify domestic politically exposed persons. As an individual is either foreign or domestic, the requirement will simply be to identify politically exposed persons (PEPs).

A Politically Exposed Person (PEP) is an individual who holds or has ever held one of the following offices or positions:

a)      a head of state or government; 
b)      a member of the executive council of the government or member of a legislature; 
c)      a deputy minister or equivalent; 
d)      an ambassador or an ambassador’s attaché or counsellor; 
e)      a military general or higher rank; 
f)      a president of a state owned company or bank; 
g)      a head of a government agency; 
h)      a judge; or
i)      a leader or president of a political party in a legislature.

In addition to your requirement to identify PEPs, you must identify individuals who are the Head of an International Organization (HIO).

Head of International Organization (HIO) is an individual who is either the head of an international organization established by the governments of more than one country; or the head of an institution established by an international organization.

Below are three examples of international organizations:

  • World Health Organization
  • North American Treaty Organization (NATO)
  • United Nations

You must also identify relatives (mother, father, child, spouse/common law partner, spouse’s/common law partner’s mother or father, brother, sister, half-brother, half-sister) or close associates of PEPs or HIOs.

We have amended the language in section 1 of the NAAF and KYC Update Form to reflect the new requirements. This question must be answered as part of the approval process.

If you are not sure a client qualifies as either a PEP or HIO, or a relative or close associate of a PEP or HIO, please contact the compliance department at for further guidance.

As always, if you have any questions or comments, contact the Compliance Department by email at