Unexplained Wealth Orders - Stokoe Partnership

Partner Bambos Tsiattalou comments on the news that unexplained wealth orders against politically exposed persons trigger a due diligence alert for banks, in Thomson Reuters Regulatory Intelligence.

Bambos’ comments were published in Thomson Reuters Regulatory Intelligence, 1 August 2019, and can be found here.

“The National Crime Agency (NCA) has new unexplained wealth orders (UWOs) against politically exposed persons (PEPs) in the pipeline, including against Russians, it said. This is triggering a possible significant need, identified by lawyers, for banks to undertake extra due diligence.

“If there are ongoing concerns, financial institutions can always review the due diligence process, which would be particularly advisable in respect of customers who have been made the subject of a UWO as a result of their association with a PEP,” said Bambos Tsiattalou, founding partner, Stokoe Partnership Solicitors.

“Such individuals may not have been seen by the institution as a risk when they first became a customer and it would be advisable therefore that enhanced due diligence checks are carried out as soon as the bank is alerted to the increased risk,” he said.

In July 2018 the London High Court dismissed an application by Mrs Zamira Hajiyeva to discharge a UWO on grounds that included that her husband was not a politically exposed person. The NCA has subsequently identified him as a “jailed Azerbaijani banker”.”