AML for government enterprises
UBO's in government operations
A state-owned enterprise (SOE) is a legal entity that is created by a government in order to partake in commercial activities on the government's behalf. It can be either wholly or partially owned by a government and is typically earmarked to participate in specific commercial activities. Some SOE’s are very complex, such as Sonangol Energy in Angola, and others are simple, perhaps existing for nothing more than providing amenities for staff.
SOE’s are generally excluded from CDD by the provisions of the legislation and laws in place in the country of jurisdiction. However, that does not mean SOE’s are wholly exempt, or that there are no UBO’s.
We recommend checking the laws in the country you are interested in, something that MVSI can assist with.
At a minimum, a government enterprise will still be required to be examined in accordance with Simplified Due Diligence procedures, which should include determining the senior controlling official, formally verifying their identity, and conducting the appropriate AML, CTF and PEP watchlists checks.