According to research conducted by a prominent global nonprofit entity investigating corruption, the Government of Libya has sent a list, containing over 240 names of Libyan expats, to the United Kingdom, seeking to recover government funds stolen by senior PEPs. Several general officers are known to be residing in the UK, and they reportedly have unexplained wealth. Libya wants the return of stolen money, but it has not has much success to date.
Allegedly, there has not been very much cooperation, on the part of the UK, in responding to Libyan government inquiries. By now, many of these PEPs would have had the opportunity to move their illicit wealth around the globe, so the prudent move for compliance officers, whose bank numbers any affluent Libyan expats as clients, would be to revisit those clients, and institute enhanced due diligence, as well as a look back into her accounts. Perhaps you did not have any information that might cause you to consider the client to be a PEP, at account opening; take another, good look. Could he be a former field-grade or general officer ?