Ultimate Beneficial Owners (UBO) Between Identification and Verification

Author: Alaa Saleh Ghaith, CAMS-Audit

Establishing effective policy and processes to identify an ultimate beneficial owner (UBO) is essential in combating money laundering and terrorist financing. All UBOs should be identified, declared, verified (where applicable) for all new and changes to existing accountholder accounts and financial services and products provided to occasional (walk-in) accountholders. These procedures must require proper due diligence and may identify unusual transactions, and possibly report the suspicious transactions. International AML standards and regulations (i.e., the Financial Action Task Force [FATF] Recommendations, the Financial Crimes Enforcement Network [FinCEN] and the Basel Committee principles), and local regulatory requirements impose legal and regulatory obligations on financial institutions (FIs) to identify UBOs, these obligations will be discussed in this white paper.

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