If we start with the presumption that the politically exposed person's regime is about corruption, we have to decide society's appetite for corruption. Are we concerned only with corruption on a grand scale, where many thousands of millions of dollars are plundered from state coffers? Does that even fall within the technical definition of corruption?

Are we not also concerned with benefits accepted by police and other enforcement officers to not do their job and to not investigate, or even to sabotage an investigation, into a serious crime? And if that concerns us, are we not also concerned with local authority officers who accept bribes not to enforce building or public health regulations?

Is there a point, somewhere between taking an apple for the teacher and paying an immigration officer to create a secret channel through a port so that persons can enter without any record that we can mark as being the limits of how corrupt it's OK to be? 

Is there a difference, other than a political difference, between a foreign politically exposed person and one who has come to be termed "domestic."

Does society's appetite for corruption not take account of the myriad ways that populations are both the beneficiaries and victims of favoured treatment by someone in authority? Is an honest society a zero-sum game?

To focus on the regulatory position, as defined by the Financial Action Task Force at the behest of regulators, is to diverge from the scale of corruption as it is practiced across the world. 

But more, to accept the regulatory position which says a regulated business has an obligation to pay special attention to a limited range of persons who are specified denies two things:

1. whatever the regulations say, anyone who accepts benefits arising from corruption, wherever it arises, is a money laundering; and
2. any risk based approach, which is the bedrock of suspicion and therefore at the heart of all counter-money laundering systems,  takes account of the function, not of the job title. 

For this reason, the regulatory approach, as it is developing, increases the risk that a financial institution will in fact launder the proceeds of corruption and that criminal proceedings may flow.

That only leaves one major point: while there is a list, and that list specifically includes some persons and specifically excludes others, there is also a catch-all: if, later, someone not on the list turns out to be corrupt and to have benefited from his office, regulators have reserved to themselves the power to say "you should have looked more carefully."

Now, let's relate that to the real companies, real policies and real people in the real world. Enquire now.