To comply with the Anti‐Money Laundering/Counter‐Terrorism Financing (AML/CTF) legislation, we need to collect and verify information about each beneficial owner.
A beneficial owner is an individual who ultimately ‘owns’ or ‘controls’ an entity:
- ‘Owns’ means owning 25% or more of the entity. This can be directly (such as through shareholdings) or indirectly (such as through another company’s ownership) or a combination of both direct and indirect holdings.
- ‘Controls' includes control as a result of, or by means of, trusts, agreements, arrangements, understandings and practices, and includes exercising control through the capacity to determine decisions about financial and operating policies. This may be 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 can be identified.