Skip to main content

Ultimate Beneficial Owner

The banks are finally catching up with the Fourth European Commission AML Directives.

Which part of the directive, in particular?

The ultimate beneficial owner (UBO). It is stated, finally, explicitly, in the directive on how a legal person or a legal arrangement couldn't ever be the ultimate beneficial owner.

In the past year I was servicing-to-clear the AML/KYC requests from the banks/regulatory bodies, however, almost all (except for one) didn't insist on receiving the data of a natural, physical person that is the ultimate beneficial owner of the whole fund. The information about a legal person (which by definition of the law, could mean an entity) seem to suffice for them.

Which is a wonder as the directive had been implemented since May 2015, and is due for full implementation this upcoming June 2017.

Now, less than 3 months into the full incorporation of the directives into the respective jurisdictions national law, they began to panic as in the directive it is an absolute requirement to maintain a centralized (warranted to be publicly accessible) UBO register.

And us, being the information provider, had also figured out that the requests are not as straightforward as we thought it would. When it involves individuals, the banks/regulatory bodies are being difficult. They want to know everything - where do they stay, their utility bills, what are the origins of the funds,... None more than the past 3 months and certified by a lawyer/public notary (including the information of these registered notaries as well)...

Comments

Popular posts from this blog

The Virginity Fraud

2 myths of women's sexuality:
1) First time of sexual intercourse is marked by bleeding
2) Hymen will break and be gone foreverThe 2 women, Nina Dølvik Brochmann and Ellen Støkken Dahl, are medical students and authors of The Wonder Down Under, easily demyths the 2 centuries-old belief in their recent sexual education TED Talk: https://youtu.be/fBQnQTkhsq4Briefly, turned out that hymens come at different shapes and sizes, i.e. stretchable, with small, many holes, or large holes in the middle, which makes it impossible to be a measure of women's virginity. How to make a measure out of something that is not a constant? If it is stretchable or sufficiently spacious to allow penis to penetrate through, it doesn't have to break and bleed, and remarked that a woman is still a virgin. Medical professionals have known these for many centuries, but the myths are still prevalent in the societies. Why are these facts not highly publicized? Because it is being used to surpress women i…

2017 Lessons

Receiving the feedback from my boss and my mentor was easy - they are all very positive. Those that are not, they have been work in progress. But I'm going to push my limit further - I'm still not satisfied with where I am now. A few learning points for 2017 (which haven't ended yet - I might have an update) below, however:1) Never be afraid to speak up - be it on a new, more efficient approach on doing things (ofc, research them well first before presenting it), be it saying no and pushing things away (due to lack of capacity and inevitable compromises of quality), be it asking for help (you'll be surprised on how people are happy if you ask for their help as they feel that they're worth much more than they think of themselves). You need to speak up to get what you want. Nobody can read your mind and nobody will know what you want unless you say it out loud. 
Moving forward: Learn to be more tactful. Learn to speak with confidence in front of a few more people th…

Working Tips

Growing up is growing pains. Hurts, but it's necessary to go through. When I first started working, the transition was hard, but I learnt a lot. Here are 3 lessons I found the most invaluable till now. 1) Setting expectations too high. It's true that in order to shine we have to give a 100%, but often times, when we were still young and energetic, we overestimated our measure of 100%. It is usually our 120-150%. Giving this overpowering 100% everyday is not sustainable - eventually you'll reach a burnout point. Reduce what you thought is 100%, not so much, but enough for you to do your job well, make your supervisor happy, and sustain for a much longer period of time. 2) Smile. An often underestimated value in the workplace. Everybody loves people who always smile to them, acknowledging their presence instead of ignoring them. You don't necessarily have to greet them cheerily and ask them sincerely how are they doing (although this is a super good time to practice the …