Hi Mathew,
Do we need to identify Beneficial Owners within the software as part of the CDD?
I see M L Verify as my “external” client data for ML purposes and do not want to populate with anything too detailed unless absolutely necessary.
HI @Bagpipe
Under the Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017 (MLR17), beneficial owners (for companies, LLPs and Partnerships) are those with 25% or more ownership.
Where the customer has beneficial owners, you would need to identify the beneficial owner and take reasonable measures to verify them, including verifying the identity of the beneficial owners.
It may be a good idea to add these to your client record in MLVerify and add the necessary checks.
If they’re an individual, you can simply add them as an associated person with the type of “Beneficial Owner”:
If they’re another legal entity, such as a limited company as an example, you would need to add them as a new client. However, you can add a note to the record, and use client tags to create a sort of relationship between them, if that makes sense?
Hi Mathew,
I knew about the 25% but all of the associated persons so far (apart from one) were directors and PSC’s. I regularly check the PSC details at Companies House. Just had a “wobble” but need to keep this detail in mind…so thanks for the update.
Would like to discuss sometime where to store items such as “client monitoring review checklists” as they really need to be kept with the data on ML Verify and not just on our internal client files.