Appendix G: Field Mission Survey
Role of FIU in Supporting Implementation of PEP Standards Questions for FIUs 79. What is your role in relation to AML/PEPs (if applicable, beyond that of a FIU)? 80. Have directives been issued to financial institutions to explain how to report PEP STRs? 81. Can you identify PEP-related STRs? If so, how? Do you recommend the use of a check-box on the STR form? 82. How are PEP STRs processed and analyzed? 83. How are PEP-specific reports produced? How are they shared with investigation or prosecution agencies? 84. Do you maintain statistics on PEP STRs? 85. Do you produce PEP typologies, PEP threat assessments, or other information to support firms in their compliance with legal and regulatory obligations? 86. Does the FIU inform the supervisor about banks that are not submitting STRs and/or STRs on PEPs? 87. Is there coordination among stakeholders in the private and/or public sector?
National and International Cooperation Questions for Banks, Regulators, and FIUs
National Cooperation 88. What kind of cooperation has been established so far on PEPs and PEPs STRs with national authorities (for example, the FIU, the police, customs, and other financial institutions/supervisors)? 89. How is the cooperation facilitated? (Memorandum of Understanding/multidisciplinary teams)? What is the process? 90. Are there any restrictions on the ability to exchange information between national agencies? 91. What is the relationship between the supervisor and the FIU? 92. What is the relationship between the supervisor and the law enforcement agencies, including prosecutorial authority?
International Cooperation 93. What kind of information sharing and cooperation is there with foreign affiliate financial institutions and correspondent banks? 94. What kind of cooperation has been established so far on PEPs with foreign supervisory authorities or FIUs and law enforcement agencies? 95. How is the cooperation facilitated? (Memorandum of Understanding?) 96. Are there any limitations on the type of information that can be exchanged with foreign authorities? (Please provide examples.)
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