70. Are reporting entities required to enforce enhanced due diligence policies and procedures regarding politically exposed persons?

"Number 7

In respect of the risk factors set out in Article 6(c), high risk situations where banks and financial institutions should apply enhanced CDD measures include but are not limited to the following:

(a) Customer risk factors:

     (1) The business relationship is conducted in unusual circumstances.

     (2) Non-resident customers.

     (3) Legal persons or arrangements that manage the assets of third parties.

     (4) Companies that have nominee shareholders or shares in bearer form.

     (5) Activities that are cash-intensive or susceptible to money laundering or terrorism financing.

     (6) The ownership structure of the legal person appears unusual or excessively complex with no visible economic or lawful purpose given the nature of the company’s business.

     (7) Business relationships conducted in or with countries as identified by the Financial Intelligence Unit under section 31(a) of the Law.

     (8) Politically exposed persons ("PEP") or customers linked to a PEP.

     (9) High net worth customers, or customers whose source of income or assets is unclear.

     (10) Businesses/activities identified by the FIU, the Central Board, the CBM or the FATF as of higher money laundering or financing of terrorism risk."

Source: Number 7 (a), Central Bank of Myanmar Directive for the CDD Measures, 2015

Commercial activities conducted by Politically Exposed Persons are considered "customer risk factors".