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Financial advisory
RES5Financial Advisory Services✓Meridian Capital onboarded Harbourline Pte Ltd in 2023, when its beneficial owner Mr Oh was a private businessman. In August 2026 the firm's periodic database scan flags that Mr Oh has been appointed chief executive of a state-owned corporation. The relationship manager says nothing needs to change because Mr Oh was screened when the account was opened. What must the firm do?
Guide ch.7.9.17. Senior executives of state-owned corporations hold prominent public functions, and the guide expects system scanning of the client database after the relationship has commenced precisely because a client may become a PEP later. Enhanced due diligence for PEPs includes senior management approval to establish or continue business relations, establishing source of wealth and source of funds, and increasing the degree and nature of monitoring.
PEP status raises the risk score and triggers enhanced due diligence; it is neither a ground for closure nor a suspicious transaction in itself.
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