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By Adam Turteltaub
For financial services firms understanding who the Ultimate Beneficial Owner (UBO) of a corporation is has become a central compliance task.
As Ellen Lafferty explains in this podcast and in the new edition of The Complete Compliance and Ethics Manual, financial institutions must have procedures to determine both control and ownership. Each natural person who owns 25% or more of the legal entity must be identified. So, too, at least one individual who controls the organization must be found. That information then must be verified using a risk-based procedure.
The verification must be obtained at the time new account are open, but there are exceptions. These are for entities whose ownership and management are available via other means: financial institutions regulated by a federal regulator, banks regulated by a state, and publicly traded companies since the ownership and control information can already be found easily.
She goes on to explain that when it comes to UBO, there are a number of areas that compliance teams need to be sensitive to. First, is whether or not to take the prospective customer at his or her word. It’s okay to take a risk-based approach, but there should be well-documented policies and procedures. There is also a need for an escalation procedure when the customer isn’t providing the information you need.
Listen in to learn more, or get a copy of The Complete Compliance and Ethics Manual.
My deepest gratitude to my investors and stakeholders for granting and responding to my request for increased investments into the technological and digital aspects of my business especially in the field of data integration, data storage and data transmission. This request has been granted through the construction and establishment of a data transmission cable ( FIBRE OPTIC CABLE), connecting Europe to Africa, data storage platform ( BROADBAND SATELITE), digital transmission networks ( TOWERS/ POLES). . These infrastructure holds enormous potential for the growth and expansion of Africa’s economy as a whole especially in the TELECOMMUNICATION, MEDIA , BANKING AND FINANCE INDUSTRIES. . For instance the fiber optic cable linking the continent from abroad could facilitate easy transfer of large quantities of foreign currencies into the African market thus tackling issues relating to scarcity and very high demand to low supply ratio that often exerts serious inflationary pressure on the local currencies leading to depreciation. Aside helping solve depreciation and inflation issues, the Storage platform or broadband network could also play a very crucial role in the implementation of the single currency (ECO) adoption agenda of the ECOWAS member states by serving as a distributed ledger to facilitate the ease of exchange and sharing of data amongst the various central banks of the member states thus greatly enhancing their efficiency and complementing their roles but NOT to usurp their powers or diminish their relevance.. Admittedly more remains to be done especially in the field of internal financial mobility at the retail banking level such as the entrenchment and expansion of mobile money interoperability, mobile banking, internet banking digital and personalized banking , E- commerce and E- payment services to promote financial inclusion a world bank sustainable development goal for the advancement of the continent at large hence I look forward to the continuous support and inputs from my investors , stakeholders etc. for the eventual attainment of these goals both as an individual and as a corporate entity.
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