September 13, 2019

Navigating Ultimate Beneficial Ownership (UBO) Across Jurisdictions

Information regarding beneficial ownership provides transparency and plays an important role in the fight against corruption, tax evasion, and money laundering. Consequently, and consistent with laws around enacted by various jurisdictions around the world, customer due diligence is a required and fundamental aspect of anti-money laundering programs. Identifying the “customer” in financial transactions, however, often proves difficult if the direct owner of a company is not necessarily the person who ultimately controls or benefits from it (the ultimate beneficial owner). Complex company structures often disguise the ultimate beneficial owner, sometimes for legitimate reasons but also may provide secrecy needed for criminal activity. Lack of clarity regarding the regulatory requirements related to identification of “ultimate” beneficial owners.