CeMAP FRE2 Money Laundering, Proceeds of Crime & Data Protection question: Okafor stood down

CeMAP FRE2Money Laundering, Proceeds of Crime & Data Protection

Mr Okafor stood down as a foreign government minister on 31 March 2026. In September 2026 he asks Calder Bank for a remortgage. There are no other higher-risk factors. What does MLR 2017 reg 35 require?

A Standard CDD, because he stopped being a PEP when he left office
B PEP measures for at least 12 months after he left office, so they still apply
C PEP measures for at least five years after he left office
D PEP measures only if he returns to public office within two years

Show the answer and explanation

Answer: B. PEP measures for at least 12 months after he left office, so they still apply

Under MLR 2017 reg 35(9), when a person stops being entrusted with a prominent public function, the firm must continue the PEP measures for at least 12 months after that date, or longer if it considers this appropriate to address the risk. Mr Okafor left office about six months before applying, so enhanced due diligence still applies. Five years is the reg 40 record-keeping period, not a PEP rule.

Common mistake

Dropping PEP measures the day the person leaves office.

Practise more FRE2 Money Laundering, Proceeds of Crime & Data Protection questions

Exam-style questions with worked answers, then full timed mocks. Free to start.

Start practising →

Study note: Money Laundering, Proceeds of Crime & Data Protection CeMAP FRE2practice questions & mock exams

Related CeMAP FRE2 questions

Leon closed his savings account and redeemed his mortgage with Harbour Bank last month. He makes a written request that the bank erase all the personal data it holds about him. What should the bank do with the identity records it obtained for customer due diligence?On Tuesday 3 November 2026 Ferrier Bank's nominated officer submits a SAR asking the NCA for a defence against money laundering (DAML) so the bank can release a customer's completion funds. The NCA does not respond. Assuming no bank holidays, when is consent treated as given?A lender with total worldwide annual turnover of £600m commits a serious UK GDPR infringement that falls in the higher band of fines. What is the maximum fine?

Build a daily practice habit — a few exam-style questions a day, with worked answers. Free to start.

Start practising →

Original practice material mapped to the published CeMAP FRE2 learning outcomes. Independent, not endorsed by Walbrook (formerly LIBF). Verify figures and rules against current guidance before relying on them.