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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)...


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