A Politically Exposed Person (PEP) is an individual who holds, or has held, a prominent public position that may make them vulnerable to corruption or involvement in money laundering and terrorist financing. Under the Proceeds of Crime (Money Laundering) and Terrorist Financing Act (PCMLTFA) and FINTRAC regulations, Robinhood Canada is required to perform enhanced due diligence on PEPs, their family members, and their close associates.

Per FINTRAC definitions, PEPs are classified into 3 primary categories:

• Foreign PEP: An individual who holds or has held a prominent public position in or on behalf of a foreign state. Examples include Heads of State, members of government or a legislature, and high-ranking military officers.
• Domestic PEP: An individual who holds or has held a prominent public position in or on behalf of the Canadian federal or provincial government. This includes Governors General, Premiers, heads of government agencies, and mayors of certain municipalities.
• Head of an International Organization (HIO): An individual who holds or has held the position of head of an international organization established by the governments of states (e.g., the UN or IMF), or the head of an institution of such an organization.

The regulatory requirements for PEPs also extend to those closely connected to them:

• Family members: Includes a PEP’s spouse or common-law partner, children, parents, and siblings. It also includes the parents of the PEP’s spouse or common-law partner.
• Close associates: Individuals who are closely connected to a PEP for personal or professional reasons. This includes individuals who have close business relations with a PEP or who share joint beneficial ownership of a legal entity or arrangement.

If you are identified as a PEP, a family member, or a close associate, we are required by Canadian law to take additional steps to verify your identity and the source of your funds. This may include:

• Providing additional documentation regarding your occupation.
• Verifying the specific source of the wealth used to fund your account.

These measures help us comply with our legal obligations and keep our platform secure. If you have questions about your status or the information requested, please contact support.