The Politically Exposed Persons Regime

Held on Wednesday, June 15, 2016

With support from Eversheds


  • Mark Turkington (UK head of sanctions, HSBC)

  • Stephen Lock (head of group financial crime prevention, Old Mutual)

  • Dr Richard Alexander (SOAS)

  • Zia Ullah (partner, Eversheds)



What should we be talking about at this round-table?
Email your suggestions for the agenda to Harry Atkinson

The PEP regime is a big deal. It has recently hit the popular press because it turns out that our own MPs and members of the Lords may find themselves defined as ‘politically-exposed’ – and that can make it very difficult to do even routine financial business.

Since our regulators don’t want to incur the wrath of Westminster, that is an anomaly that will be sorted out (if it hasn’t been already). But the PEP net is exceptionally wide, and it can catch people for whom it was not intended. And that can hurt the City of London.

So, it is worth looking at just who is (and is not) a PEP, in particular:

  • How the regulators make that judgment;
  • What the sanctions for non-compliance are; and
  • What can City institutions do to minimize the impact.

I am delighted that we have been able to put together a distinguished panel:

  • Mark Turkington is the UK head of sanctions at HSBC, having joined from National Australia Bank where he was deputy global head of financial crime risk. In his spare time, he is finishing a PhD on international measures to combat financial crime.

  • Steve Lock is head of group financial crime prevention at Old Mutual, with a brief that covers AML, sanctions, anti-bribery compliance, as well as tax evasion.

  • Richard Alexander is a lecturer in financial law at SOAS. Amongst other publications, he is the author of “Insider Dealing and Money Laundering in the EU: Law and Regulation”.
  • Our host, Zia Ullah, is equally distinguished. He is a partner at Eversheds, specializing in financial crime and regulatory compliance issues. He was previously the global head of sanctions at Barclays.