Family member refers to a parent, step-parent, child, step-child, adopted child, spouse, sibling, step-sibling and adopted sibling of the politically-exposed person.
In determining who close associates are, Financial Institution (“FI”) may consider factors such as level of influence the PEP has on such person or the extent of his exposure to the PEP. FI may rely on information obtained from public sources and information obtained through customer interaction.