1

Introduction to this guide

1. 1.1

   [Insert firm name] is required by the money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017 (MLR 2017), SI 2017/692 (MLR 2017), as amended, to put systems and controls in place to combat money laundering, terrorist financing and proliferation financing.

1. 1.2

   Our AML, CTF and counter-proliferation financing policy contains the procedures we have developed to comply with these obligations. This includes a requirement to conduct client due diligence (CDD), ie to:

   1. 1.2.1

      identify and verify the client’s identity;

   1. 1.2.2

      identify the beneficial owner where this is not the client; and

   1. 1.2.3

      obtain details of the purpose and intended nature of the business relationship.

1. 1.3

   This document provides guidance on the second requirement, ie to identify the beneficial owner.

2

What/who is a beneficial owner?

1. 2.1

   A beneficial owner is the natural person(s) who:

   1. 2.1.1

      ultimately owns or controls the client; or

   1. 2.1.2

      on whose behalf a transaction is being conducted.

1. 2.2

   The concept of beneficial ownership should not be confused with a situation where a client appoints someone to act on their behalf.