Updated

GL-R-03

Glossary · Due Diligence and compliance

RCA - Relative and Close Associate (PEP relatives)

RCA (Relative and Close Associate) — the relatives and close associates of politically exposed persons (PEPs), who are also checked with heightened attention.

Full glossary
link with a PEPthrough kinship
enhancedalso checked
transparentthe best protection

01 / In 30 seconds

The short answer

What it is
RCA — the relatives and close associates of a politically exposed person (PEP)
Who it concerns
A PEP’s spouses, children, partners and close business associates
Why it matters
A PEP’s funds or influence may pass through them
Bottom line
Such persons also undergo enhanced checks
How to use it
Disclose the link in advance and explain the sources

02 / In plain words

What RCA means

RCAs (relatives and close associates) are the relatives and close associates of a politically exposed person (PEP). Compliance extends its heightened attention to PEPs not only to the official or politician themselves but also to their circle: spouses, children, parents, business partners and others close to them, because assets, influence or corruption risks linked to the PEP may pass through them.

The logic is simple: if the PEP themselves is under enhanced scrutiny, then their inner circle also needs attention — otherwise funds of dubious origin could easily be “hidden” with those close to them. That is why banks and citizenship programmes establish whether the client is a relative or close associate of a PEP and, where there is such a link, apply enhanced due diligence (EDD), just as to the PEP themselves.

For a person connected with a politically exposed person this means: concealing the link is pointless and harmful — the check will reveal it, and concealment will arouse suspicion. The right strategy is to disclose the link in advance and evidence your own, independent sources of income and funds particularly thoroughly. We help RCA clients prepare a transparent file so that the link with a PEP does not become an obstacle.

A case from practice

The child of a senior official applies for citizenship. As an RCA they undergo an enhanced check. We disclose the link in advance and evidence their own, independent income in detail — so that it is clear the funds were earned by them. A transparent file removes the questions, and the application is approved.

Who RCA status concerns

  • Spouses and children of politically exposed persons
  • A PEP’s parents and close relatives
  • A PEP’s business partners
  • Going through due diligence
  • Opening accounts and obtaining citizenship
  • Evidencing independent sources of funds

03 / What it covers

What matters about RCAs

01

Who it is

  • A PEP’s relatives
  • Close associates
  • Business partners
02

Why it matters

  • A PEP’s assets through them
  • Influence and risks
  • Hiding with those close
03

Consequences

  • Enhanced checks
  • As for the PEP
  • Attention to sources
04

Protection

  • Disclose the link
  • Your own sources of funds
  • Transparency

04 / How it works

How RCAs go through the check

Step 1

Establish the link with the PEP

Step 2

Disclose it transparently

Step 3

Evidence your own sources of funds

Step 4

Pass the enhanced check

Step 5

Approval

05 / Key facts

What you need to know

01

RCAs are the relatives and close associates of a PEP

02

Heightened attention to PEPs extends to their circle

03

Assets and influence may pass through those close to them

04

RCAs undergo enhanced checks, just like the PEP

05

Concealing the link is pointless — the check will reveal it

Common mistakes

  • Concealing kinship or a link with a PEP
  • Not evidencing your own independent sources of funds
  • Assuming PEP status concerns only the official
  • Underestimating the depth of the enhanced check
  • Not disclosing business links with a PEP

06 / Expert advice

Klara Rihter

How to prepare in advance

If you are a relative or close associate of a PEP, disclose the link in advance and evidence particularly thoroughly your own, independent sources of income and funds — that they were earned by you and are not linked to the PEP. An enhanced file is prepared, as for the PEP themselves. Then the link with a politically exposed person does not become an obstacle, and the check goes smoothly.

What we do for you. We help clients connected with politically exposed persons pass the enhanced check: we disclose the link in advance and thoroughly evidence your own, independent sources of funds. Transparency is the best protection here: it removes suspicion and prevents the link with a PEP becoming an obstacle to an account or a passport.

Klara RihterBanking compliance and source of funds specialist

07 / Questions

Frequently asked questions

Relatives and close associates — the relatives and close associates of a politically exposed person (PEP): spouses, children, parents, business partners.

Because a PEP’s assets and influence may pass through those close to them. Otherwise funds of dubious origin could be “hidden” with relatives, bypassing controls.

Yes, where there is a link, enhanced due diligence (EDD) is applied, just as to the PEP themselves — with particular attention to the sources of funds.

No, and it should not be: the check will reveal it, and concealment will arouse suspicion. The right strategy is to disclose the link in advance and evidence your own sources of funds.

Not by itself, if your income is lawful and transparent. It is important to evidence independent sources of funds. We help prepare such a file.

Besides relatives — business partners and persons with close business or financial ties to the PEP. The exact circle depends on the requirements of the particular check.

Author: Klara Rihter

Reviewed by: Dmitry Nagy

Sources: FATF — on PEPs and associated persons

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Anna Kovalevskaya, lead lawyer at BRIDGES GLOBAL
Anna KovalevskayaLead lawyer, citizenship and residency, 12 years of practice