Guide to beneficial ownership for staff

The following Risk & Compliance precedent provides comprehensive and up to date legal information covering:

  • Guide to beneficial ownership for staff
  • 1 Introduction to this guide
  • 2 What/who is a beneficial owner?
  • 3 Types of beneficial owner
  • 4 Companies and LLPs
  • 5 Partnerships
  • 6 Trusts
  • 7 Foundation or other legal arrangement similar to a trust
  • 8 Estate of a deceased person in the course of administration
  • 9 Other legal entity or legal arrangement
  • More...

Guide to beneficial ownership for staff

    1. 1

      Introduction to this guide

      1. 1.1

        [Insert organisation name] is required by the Money Laundering Regulations 2017, SI 2017/692 (MLR 2017), as amended, to put systems and controls in place to combat money laundering and terrorist financing.

      1. 1.2

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

        1. 1.2.1

          identify and verify the customer’s identity;

        1. 1.2.2

          identify the beneficial owner where this is not the customer; 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.

    1. 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 customer; 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 customer appoints someone to act on their behalf. See our AML and counter-terrorist financing policy, section [insert section title or number] for the steps to take where a person purports to act on behalf of the customer.

    1. 3

      Types of beneficial owner

      1. 3.1

        The MLR 2017 identify six categories of customer that may have a beneficial owner:

        1. 3.1.1

          corporate body, ie companies and limited liability partnerships (LLPs) which is not a

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