Factors to Consider
The ML/TF risk of a PEP who is no longer entrusted with a
prominent public function must be assessed, and effective action
taken to mitigate this risk.
Possible risk factors are:
the level of (informal) influence that the individual could still
exercise;
the seniority of the position that the individual held as a PEP; or
whether the individual’s previous and current function are linked in
any way (e.g., formally by appointment of the PEPs successor, or
informally by the fact that the PEP continues to deal with the same
substantive matters).
