The political tension in the Middle East has had unprecedented effects on governments in Tunisia and Egypt. As these governments have been forced out of office the presidents and their family members have been added to sanctions lists, which require their assets to be frozen. The ex-president of Tunisia, Zine El Abidine Ben Ali, and his family members have been added to the HM Treasury, European Union and Switzerland's State Secretariat for Economic Affairs list. The ex-president of Egypt, Hosni Mubarak, and his family were also added to Switzerland's State Secretariat for Economic Affairs list and the EU has debated adding them as well. The US Treasury's Financial Crimes Enforcement Network has issued guidance on identifying Politically Exposed Persons (PEPs) and noted the increased risks associated Egypt.
As similar unrest spreads to other countries the need to know if your institution is dealing with PEPs, in particular the PEPs associated with such countries, is dramatically increasing. Whether your institution already has a PEP screening program is place or not, it is time to increase your focus on the Middle East.
But how do you know where to look next? Yesterday's Tunisia is today's Libya and could be tomorrow's Bahrain. The solution that you use to execute your sanctions and EDD screening has to be as flexible and fluid as the political situation in such countries. A one-size-fits-all solution is likely not the best option in an environment that is changing so rapidly. Having the ability to focus on those areas that present the most risk should become a "must have" option in the solution you choose to employ. Without such flexibility, your processes could become unduly burdened by false positives — and an unwieldy process is not a fair trade-off for better risk mitigation when there are solutions available that will allow you to do both.