If you did not have a chance to review the March FSA report on Coutts, you will find a number of good examples of what NOT to do when dealing with high-risk international clients. There's also a list in the report regarding Politically Exposed Persons (PEPS) and high-risk clients that I recommend you review, to see whether your programme measures up:
(1) Gather sufficient information about a prospective PEP and other high-risk customers, to establish their Sources of Wealth and income.
(2) Establish the Source of Funds received at the outset of the high-risk customer relationship.
(3) Gather sufficient information about prospective high-risk corporate customers, such as information regarding business activities, ownership and control structures and the intended purpose of the business relationship.
(4) Identify and/or assess adverse intelligence about prospective and existing high-risk customers properly, and take appropriate steps in relation to such intelligence.
(5) Keep the information on existing PEPs and other high-risk customers up-to-date.
(6) Scrutinise transactions made through PEP and other high-risk customer accounts appropriately.
These are excellent guidelines, and I recommend them; Our thanks to the FSA.