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Legal Update

English court gives guidance on when a person is “politically exposed” for AML purposes

October 2018
Mayer Brown Legal Update

In a much-anticipated decision, the High Court this week upheld the UK’s first Unexplained Wealth Order (“UWO”). The subject of the UWO, originally referred to as “Mrs A”, has now been identified as Zamira Hajiyeva, the wife of Jahangir Hajiyev, the former Chairman of the International Bank of Azerbaijan who was jailed in 2016 for embezzling tens of millions of pounds from the bank.

In the course of this decision, Mr Justice Supperstone shed some light on the definition of a “Politically Exposed Person” (a “PEP”) under the Fourth Money Laundering Directive (“MLD4”)1 in respect of stateowned companies. This is relevant not only to UWOs, but also to the requirements for enhanced due diligence and monitoring for PEPs under the MLD4.


1 Implemented in the UK by The Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017


  • Susan Rosser
    T +44 20 3130 3358
  • Jeremy Holden
    T +44 20 3130 3501
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