Educate customers about the benefit of sharing UBO information
To better serve your customers, educate them on the reasons why it will benefit them to share the details of all their holdings and corporations.
Better long-term customer relationship managementHaving this information will help your organisation learn about the true level of wealth and/or the wealth potential of the individual behind the corporation in order to build a stronger and more lasting relationship with the client for the long-term.
ComplianceYour organisation needs this information for global regulation compliance.
Obligation of the customer’s organisationSharing this information helps to fulfil the reporting and compliance requirements of the customer’s organisation.
Aquire key pieces of information from customers
Require customers to provide UBO information – advise the customer that identification and information provided will be stored securely.
Names of natural personsRequire customers to provide the names of the natural persons that are UBO of legal persons or arrangements that own more than 10% of the shares of the entity.
Purpose for layers of corporate namesWhere there are other entities listed as UBO, inquire about the purpose of single and/or multiple layers of corporate names to better understand the reason for that protection.
Changes in ownershipRequire customers (especially those rated “high-risk”) to provide updated information about changes in substantial ownership (following jurisdictional percentage requirements – i.e. 25%, 10%, etc.) whenever there is a change in ownership and at least annually.
Certificates of ownershipRequire customers to provide certificates of ownership as evidence of entitlement and retain said certificates securely.
Action steps after receiving customer information
Corroborate the information provided by the customer with outside sources besides business formation documents and adverse media searches.
Consider using advanced tools that incorporate government filings, public records and database solutions used to screen against special watchlists, and verify if names provided by customers appear on PEP lists or other enforcement lists (these tools may provide affiliated names and adverse media references associated with a UBO).
Outsource intelligence services
On more difficult cases of UBO identification, consider outsourcing intelligence services that can provide enhanced due diligence information that is not publicly available.
Bookmark corporate registries
For expedited access, bookmark online pages for corporate registries provided by government agencies in order to corroborate information provided by customers.
Create a plan to periodically review and update the customer profile.
Continue to monitor for unusual transaction activity, new KYC information (change in occupation), and perform on-going adverse media searches.
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