1. Politically Exposed Persons (PEPs)
Under Law No. 14/2023 of 28 August, and other applicable regulations concerning the Prevention and Combating of Money Laundering, Terrorist Financing and Financing of the Proliferation of Weapons of Mass Destruction, Politically Exposed Persons (PEPs) are defined as national or foreign individuals who perform or have performed prominent public functions in Mozambique, in another country or within international organisations.
The following are also covered by this definition, among others:
a) senior political or public office holders:
i. President of the Republic or Head of State;
ii. Speaker of Parliament, Members of Parliament, Presidents and members of Provincial Assemblies, and equivalent positions;
iii. Prime Minister, Ministers, Deputy Ministers, Secretaries of State, Provincial Governors, Provincial Secretaries of State and other equivalent positions or functions;
iv. Judges of the Supreme Court, Administrative Court, Constitutional Council, and their respective Secretaries-General, other high-level judicial bodies whose decisions are not subject to appeal except in exceptional circumstances, and Provincial Presiding Judges;
v. Public Prosecutors of equivalent rank to the Judicial Magistrates referred to in the previous subparagraph, and the Secretary-General;
vi. Ombudsman;
vii. Members of the Council of State, the National Defence and Security Council and other State Councillors;
viii. President and Members of the National Elections Commission;
ix. Members of the Higher Councils of the Judiciary and the Public Prosecutor’s Office;
x. Members of the Board of Directors of the Bank of Mozambique, other regulatory and supervisory authorities of the financial sector;
xi. Heads of diplomatic and consular missions.
b) Senior Officers of the Defence and Security Forces;
c) Members of the governing bodies of public companies and companies wholly or majority-owned by the State, public institutes, public associations and foundations, public establishments, irrespective of the manner of their appointment, including management bodies of companies belonging to local public business sectors;
d) Members of the Board of Directors, directors, deputy directors and/or persons who perform or have performed equivalent functions within an international organisation;
e) Members of the leadership bodies of political parties;
f) Members of local administrations and municipal authorities;
g) Leaders of religious denominations;
h) The following are also treated as Politically Exposed Persons: family members and persons closely associated with the individuals referred to above, namely:
i. spouses or persons living in a de facto union with them;
ii. parents, children and their respective spouses or persons living in a de facto union with them.
i) persons with recognised and close corporate or commercial relationships:
i. any natural person publicly known to be a joint owner, with a shareholding equal to or greater than 10% of the share capital, together with the holder of a senior political or public office in a legal entity, or who maintains close business relations with such office holder;
ii. any natural person who owns share capital amounting to 10% or more, or voting rights in a legal entity or in the assets of a collective interest arrangement without legal personality, publicly known to have as its sole beneficial owner the holder of a senior political or public office.
j) holders of political and public offices equivalent to those referred to in paragraph a) of this definition;
k) the status of politically exposed person ceases two years after the date on which the circumstance giving rise to such qualification ends.
2. Enhanced Due Diligence Measures Applicable to PEPs
Absa Bank Mozambique operates in accordance with high standards of ethics, integrity, transparency and regulatory compliance, adopting appropriate measures to prevent the use of the financial system for illicit purposes.
In this context, the Bank applies enhanced due diligence measures to business relationships and transactions involving Politically Exposed Persons (PEPs), their representatives, beneficial owners, family members and closely associated persons, whenever required by applicable legislation or by the Bank’s risk assessment.
3. What are Enhanced Due Diligence Measures?
Enhanced due diligence measures consist of additional identification, verification, monitoring and control procedures intended to mitigate increased risks associated with certain business relationships or transactions.
These measures aim to ensure:
- proper knowledge of the Client;
- identification of the source of funds and wealth;
- understanding of the purpose and nature of the business relationship;
- ongoing monitoring of transactions carried out.
4. When are Enhanced Due Diligence Measures Applied??
Absa Bank Mozambique applies enhanced due diligence measures, namely when:
- the Client, representative or beneficial owner is identified as a PEP;
- PEP status is acquired after the commencement of the business relationship;
- the transactions or business relationship present an increased risk of money laundering, terrorist financing or financing of the proliferation of weapons of mass destruction;
- there is a legal or regulatory obligation to do so..
5. Additional Information That May Be Requested:
Within the scope of enhanced due diligence measures, the Bank may, among others, request additional information or documentation, including:
- professional activity or public office performed;
- purpose of the account and of the business relationship;
- source of income, wealth and funds transacted;
- information regarding the reasons, nature and justification of operations or financial transactions;
- identification details of PEPs, their representatives, family members and other closely associated persons..
Whenever necessary, legal entities related to PEPs may also be analysed, in accordance with the applicable legal provisions.
6. Additional Documentation
Absa Bank Mozambique may, at any time and whenever deemed necessary for the purpose of complying with legal and regulatory obligations, as well as its internal control and risk management procedures, request additional information or documentation related to Client identification, source of funds, wealth, nature of transactions or other elements relevant to maintaining the business relationship.
7. Approval and Ongoing Monitoring
Business relationships with PEPs are subject to internal approval procedures by the Bank’s senior management bodies.
The Bank also conducts ongoing and enhanced monitoring of business relationships and transactions carried out, with the aim of ensuring consistency with the profile, activity and information provided by the Client.
Certain transactions instructed by PEPs may be subject to additional validations or authorisations provided by the Bank’s senior management, in accordance with the Bank’s defined internal controls and applicable legal requirements.
8. Confidentiality and Data Protection
All information collected within the scope of enhanced due diligence measures is treated with strict confidentiality and used exclusively for compliance with the legal and regulatory obligations applicable to Absa Bank Mozambique, in observance of data protection rules and duties of confidentiality and professional secrecy.
9. Institutional Commitment
The application of enhanced due diligence measures does not represent any value judgement regarding the Clients concerned.
These measures arise from legal and regulatory obligations intended to promote the integrity, security and transparency of the financial system
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