Saturday, October 6, 2012


Should the Opposition candidate, Capriles, win the Venezuelan presidency, tomorrow, expect that a substantial number of Chavista Venezuelan PEPs will be flying out of the country on tickets that they purchased several months ago. A number of Venezuelan nationals may appear at your bank next week, seeking to open accounts.

Your task will be to ascertain whether they are PEPs who are cleverly hiding that fact from your New Accounts staff. They may allege that they are businessmen, retired individuals, or Venezuelan nationals who are independently wealthy, due to family assets.

You must initiate Enhanced Due Diligence on all such account applicants, for if they are indeed PEPs, and you fail to identify them as such, and you allow them to become bank customers, their accounts could later be the subject of seizure and forfeiture efforts by a democratic Venezuelan government, seeking disgorgement of illicitly-acquired assets. Watch yourself this week. 

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