To comply with our Anti‐Money Laundering/Counter‐Terrorism Financing (AML/CTF) obligations, we’re required to collect and verify information about each beneficial owner.
A beneficial owner is an individual who ultimately ‘owns’ or ‘controls’ an entity.
This includes the individual, or individuals, who directly or indirectly, ‘owns’ 25% or more of the entity, or ‘controls’ the entity through decision making including an appointor, protector, trustee, director or a senior managing official.
A beneficial owner is always a natural person. Therefore, if another entity is a beneficial owner of the entity (including corporate trustees), the beneficial owner requirement (defined above) must be applied to that respective entity and so on until a natural person or persons owning 25% or more can be identified.
There may be circumstances where an individual or another entity holds shares in the client through a trustee or through a nominee on behalf of another person. This is known as non-beneficially held (NBH) shares. In these circumstances, some additional documentation is required to show the link to the underlying share holdings. We’ve created a guide for these more complex scenarios that you can access, see Beneficial Ownership Guide.
Please ensure the correct documents are uploaded showing the ultimate beneficial owners (i.e. individuals who own 25% or more) of the company for complex company shareholding structures. This may include a share certificate relating to the corporate trustee or a trust deed for the trust holding shares non-beneficially, rather than for the trust that the account is being set up for.
For more information about what documents we need depending on the underlying structure, refer to the Help Centre article Beneficial ownership requirements.