OneVest has politically exposed persons (PEPs) and heads of international organizations (HIOs) requirements under the Proceeds of Crime (Money Laundering) and Terrorist Financing Act (PCMLTFA) and associated Regulations. If you identify with either status during onboarding, OneVest will follow up with a form for you to complete and return before your funds can be invested.
What is a PEP?
Depending on your circumstances, you can have either:
- Domestic Politically-Exposed Person (PEP) status, and/or
- Foreign Politically-Exposed Person (PEP) status
Information for Domestic PEPs
As outlined by the Government of Canada, “A domestic PEP is a person who currently holds, or has held within the last 5 years, a specific office or position in or on behalf of the Canadian federal government, a Canadian provincial (or territorial) government, or a Canadian municipal government. Specifically, the person has held the office or position of:
- Governor General, lieutenant governor or head of government;
- member of the Senate or House of Commons or member of a legislature;
- deputy minister or equivalent rank;
- ambassador, or attaché or counsellor of an ambassador;
- military officer with a rank of general or above;
- president of a corporation that is wholly owned directly by Her Majesty in right of Canada or a province;
- head of a government agency;
- judge of an appellate court in a province, the Federal Court of Appeal or the Supreme Court of Canada;
- leader or president of a political party represented in a legislature; or
- mayor, reeve or other similar chief officer of a municipal or local government**.
**Note: In line with legislation across Canada, municipal governments include cities, towns, villages and rural (county) or metropolitan municipalities. As such, a mayor is the head of a city, town, village and rural or metropolitan municipality, regardless of the size of the population.
A person ceases to be a domestic PEP 5 years after they have left office or 5 years after they are deceased. You must continue to mitigate the risks associated with domestic PEPs until they cease to be domestic PEPs.”
Information for Foreign PEPs
As outlined by the Government of Canada, “A foreign PEP is a person who holds or has held one of the following offices or positions in or on behalf of a foreign state:
- head of state or head of government;
- member of the executive council of government or member of a legislature;
- deputy minister or equivalent rank;
- ambassador, or attaché or counsellor of an ambassador;
- military officer with a rank of general or above;
- president of a state-owned company or a state-owned bank;
- head of a government agency;
- judge of a supreme court, constitutional court or other court of last resort; or
- leader or president of a political party represented in a legislature.
These persons are foreign PEPs regardless of citizenship, residence status or birthplace.
Once you determine that a person is a foreign PEP, they remain a foreign PEP forever (including deceased foreign PEPs). You are not required to determine whether they are a foreign PEP again.”
What is a HIO?
As outlined by the Government of Canada, “A HIO is a person who currently holds or has held within the last 5 years the specific office or position of head of an international organization and the international organization that they head or were head of is either:
- an international organization established by the governments of states;
- an institution of an organization referred to in 1 above; or
- an international sports organization.
An institution established by an international organization does not have to operate internationally and it is possible that an institution only operates domestically, or in one jurisdiction.
The HIO is the primary person who leads the organization. For example, the HIO could be a president or CEO.
A person ceases to be a HIO 5 years after they are no longer the head of the organization or institution or 5 years after they are deceased. You must continue to mitigate the risks associated with HIOs until they cease to be HIOs.”
*Also note that the family members and close associates of PEPs and HIOs are also confirmed during onboarding. Please see more information on here on who the family members and close associates of PEPs and HIOs are.
Need Assistance?
If you have any questions, you can always reach out to our support team, and/or find more information on the following Government of Canada webpage: Politically exposed persons and heads of international organizations guidance.