Who ultimately owns the company.
WHAT IT REQUIRES
Identifying and recording individuals who ultimately own or control a company.
WHY IT EXISTS
Transparency, and prevention of concealed ownership.
WHAT SIGNIFICANT CONTROL TYPICALLY MEANS
Holding a defined proportion of shares or voting rights Power to appoint or remove directors Otherwise exercising significant influence
WHAT TO ESTABLISH
Who meets those tests, looking through corporate shareholders to individuals.
WHY LOOKING THROUGH
A company owned by another company still has ultimate individual owners.
WHAT TO RECORD
Each person's details The nature of their control When it began
WHERE
An internal register, and with the registry where required.
WHAT TO DO ON CHANGES
Update both, within the prescribed period.
WHAT HAPPENS ON FAILURE
Penalties, and difficulties with banking and counterparties.
WHY BANKS CARE
Their own obligations require identifying beneficial owners.
WHAT THAT MEANS PRACTICALLY
Account opening stalls where ownership is unclear.
WHAT TO PREPARE
A clear ownership chart.
WHY
It answers the question immediately.
WHAT TO AVOID
Nominee arrangements without proper disclosure.
WHY
They are exactly what the requirement targets.
WHAT TO TAKE ADVICE ON
Complex ownership structures.