“Restricted Persons” Definition

Certain individuals, entities and organizations and clients, collectively "restricted persons," are subject to additional limitations with respect to gifts and entertainment. If you are in doubt as to whether or not a particular Business Contact would be considered a restricted person, it is your responsibility to seek advice from the Compliance department.

  • Public officials including
    • An officer or employee of, or other person acting in an official capacity for a government, whether national, federal or local;
    • A legislative, administrative or judicial official, whether appointed or elected, including officials exercising a public function on behalf of any entity controlled or owned by a government, including but not limited to central banks, sovereign wealth funds, state-run hospitals;
    • Employees of a business venture that is determined to be majority owned or controlled by a government entity, unless the entity has been specifically exempted by the Compliance department;
    • Candidates for public office;
    • Officials of a political party;
    • Officials or agents of a public international organization;
    • Members of a royal family; and
    • Where known, the relevant person's close family members (e.g., spouse, children, parents, and siblings) and close associates (e.g., key business colleagues, personal advisers and legal entities owned or controlled by that person).
  • Regulatory and exchange personnel;
  • Credit rating agency personnel;
  • US labor union personnel;
  • US public pension plan personnel.