Tranche 2, plainly · Episode 6
When your customer is a company or a trust, you are not really dealing with it. You are dealing with the people behind it. The law calls them beneficial owners — and it wants you to find them.
Look behind the company
A company can't launder money. People do — sometimes hiding behind layers of companies and trusts. So the regime asks one simple question: who is really at the top?
beneficial owner of a person (other than an individual) means an individual who: (a) ultimately owns (either directly or indirectly) 25% or more of the person; or (b) controls (directly or indirectly) the person.
Own it, or control it
Twenty-five percent ownership — directly or indirectly. Or control, by any means. Own a quarter, or pull the strings, and you are a beneficial owner. Your job is to look through the structure until you reach a real human being.
That is beneficial ownership. Not the company on the paperwork — the person who owns or controls it. Twenty-five percent, or control. Find them, and you know who you are really serving.
Behind every entity is a person. Beneficial ownership is simply the discipline of not stopping until you have found them.