Where an existing customer is a PEP, or subsequently becomes a PEP, enhanced monitoring and customer due diligence measures must include:

(a) Analysis of complex financial structures, including trusts, foundations or international business corporations;
(b) A written record in the customer file to establish that reasonable measures have been taken to establish both the source of wealth and the source of funds;
(c) Development of a profile of anticipated customer activity, to be used in on-going monitoring;
(d) Approval of senior management for allowing the customer relationship to continue; and
(e) Ongoing account monitoring of the PEP's account by senior management (such as the MLRO).
October 2010