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There may be several links in the chain of owners. To determine who the beneficial owner is, you need to know and understand your customer’s business or organisational structure – how it is owned and controlled. It can be hard to determine the beneficial owner of a non-individual customer.Ĭustomers who are not individuals can have complex ownership structures. Your employees must follow the procedures set out in your AML/CTF program for determining, identifying and collecting beneficial owner information.ĭetermining who your customers’ beneficial owners areĭoing business with an individual has different money laundering/terrorism financing risks compared to doing business with a non-individual customer (such as a company, trust or association). The procedures must be specific to your business or organisation and its level of money laundering/terrorism financing risk.
#Hidden business ownership definition update#
how you update beneficial ownership information for a customer and manage changing risks over the duration of your business relationship.the reliable and independent documentation or electronic data you use to verify the identity documents of the beneficial owners.the information you verify about each beneficial owner and what reasonable measures you will implement to do so.the information you collect about each beneficial owner.how you determine who your customers’ beneficial owner(s) are.Your AML/CTF program must set out how you meet your obligations around beneficial owners. keeping records of how you identified each beneficial owner and verified their identity.verifying the identity of your customers’ beneficial owners.assessing the level of money laundering/terrorism financing risk your customers’ beneficial owners pose to your business or organisation.determining who your customers’ beneficial owners are.Your obligations around beneficial owners include: Note that a customer may have more than one beneficial owner. They may exert control through trusts, agreements, arrangements, understandings, policies or practices. ‘Controls’ in this case means having the power to make decisions about the entity’s finances and operations.This can be directly (such as through shareholdings) or indirectly (such as through another company’s ownership or through a bank or broker). ‘Owns’ in this case means owning 25% or more of the entity.All reporting entities must identify the beneficial owners of their customers and assess the money laundering/terrorism financing risk they pose.Ī beneficial owner is an individual who ultimately owns or controls an entity such as a company, trust or partnership. It can also protect your business or organisation from being exploited for other forms of criminal activity.
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Understanding who ultimately has control of your customer plays an important role in detecting, disrupting and preventing money laundering and terrorism financing.
