• Put in place risk management systems to determine whether a customer or the beneficial owner is a PEP. At the moment there is no requirement in the Anti-Money Laundering and Anti-Terrorist Financing Handbook and Code of Practice for Credit Unions (the AML/ATF codes) to put a risk management system in place to determine whether a customer or beneficial owner is a PEP.
• Obtain senior management approval before establishing (or for existing customers, continuing) such business relationships. Under the AML/ATF codes, larger credit unions are required to obtain senior management approval to establish or continue a relationship if the PEP became highly risky subsequent to establishing the business relationship. This measure does not capture ‘smaller’ credit unions.
• Take reasonable measures to establish the source of wealth and the source of funds of customers and beneficial owners identified as PEPs. There are no provisions for credit unions to establish the source of wealth and the source of funds of PEPs.

The proposed amendments will make specific provision for credit unions to take the above measures.