Beneficial Ownership – An Insider’s View Versus an Auditor’s Perspective

Author: Nadine N. Al Shirawi, CAMS-Audit

Ultimate beneficial ownership (UBO) is perceived as one of the primary challenges in anti-money laundering/counter-terrorist financing (AML/CTF) efforts. The related obstacles to detecting and verifying the ultimate beneficiary of financial transactions and business relations in AML/CTF-related investigations forms part of an existing hot debate in literature and the industry. In this paper, beneficial ownership will be explored from a procedural point of view as well as from an AML auditor’s perspective. The issue will particularly be investigated from a local point of view, analyzing whether there are localized more significant challenges pertaining to doing business in the Middle Eastern/GCC region, such as a large number of politically exposed persons (PEPs), high-net-worth individuals, charities, and private trusts and often nontransparent nature of doing business. Being a nontaxable jurisdiction, publicly available information on natural persons and legal entities in the GCC region is quite limited.

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