I wonder how broadly/narrowly the request to Kedipes for data is defined. I expect that there are, in practice, massive loopholes available to Kedipes and certain borrowers from the co-ops which ensure that, given the standard usage of smoke and mirrors, the whole truth need not be revealed.
Will all parties recognise that the requirements of a financial institution regarding a PEP apply also to:
family members such as a spouse, a partner, children and their spouses or partners and parents;
close associates including any individual who is known to have joint beneficial ownership of a legal entity or legal arrangement, or any other close business relations; and any individual publicly known, or known by the financial institution, to be a close personal or professional associate?
Cyprus is a member of MoneyVal (which has a focus on money-laundering and financing of terrorism) which, in general, mandates enhanced due diligence measures for all PEPs and has previously requested of Cyprus that it “strengthen” its measures with regard to ‘family members’ and ‘close associates’ and improve its identification of such persons as well as identifying when they become PEPs in their own right.
Cyprus responded that it has put laws and systems in place but, as we all know, that doesn’t mean that laws are actually policed and enforced or that systems are correctly operated (if at all) or monitored.