Spitzer: A "Politically Exposed Person"

Eliot Spitzer is a Politically Exposed Person (PEP) and not only in the way you might think. Section 312 of the Patriot Act requires US financial institutions to monitor all accounts for suspicious activities and handle all PEPs with greater scruitiny. In Spitzer’s case, his own bank had labeled him a PEP and was tracking his
financial transactions more closely than those of a “typical” customer.

So far, not so bad--maybe politicians should have their banks looking into their transactions. But--here's the problem--there is no PEP definition. The standards are so vague that you could be an “exposed person” with your bank monitoring your accounts.

This special tracking is performed through anti-money laundering software sold by such notorious outfits as Choicepoint. Choicepoint is the data aggregator which produced the infamous “felons” list for Florida elections officials in 2000. It incorrectly identified thousands of African-Americans as felons, knocking them off voting rolls, so it’s not like Choicepoint never designs bad data tracking systems.

Advertisements for tracking software describe the ability to identify an individual as a PEP, including some of the following:

* a current or former senior official in the executive, legislative, administrative, military, or judicial branch of a government (elected or not)
* a senior official of a major foreign political party
* an immediate family member of such individual; including spouse, parents, siblings, children, and spouse's parents or siblings
* Senior political party functionaries;
* Members of ruling royal families;
* Senior and/or influential representatives of religious organizations (if these functions are connected with political, judicial, military or administrative responsibilities); and
* any individual publicly known (or actually known by a financial institution) to be a close personal or professional associate of one of the above.

There'a something a little creepy about a private institution with fiduciary duties to you, the customer, using its “discretion” to monitor your accounts under such vague standards. Are your sure you are not some kind of "associate" of a the child of former official of some kind?