Beneficial Owners - non company

UBO's in other organizations

AML simplified due diligence


There are many types of businesses that operate outside the structure of a limited company. These include partnerships, trusts, clubs, not for profits, associations, and many more.  You may think that because the organisations don’t have shareholders, that they don’t have beneficial owners.

The purpose of AML Law is to control crime through making it difficult to launder the proceeds of crime into legitimate and verifiable sources of cash. Based on this underlying principle, the AML laws of every country look to who would either control or benefit, and that person or persons is deemed to be the beneficial owner. As such, no matter what type of entity your customer is, the law will describe how a beneficial owner is described for that entity type. This is why many countries use the term "persons with significant control", rather the “owner”.

In a membership based organisation for example, which is owned by its members, there are no shareholdings to be calculated, and because membership can fluctuate literally on a day to day basis, it would be useless to try and calculate ownership based on the number of current members. AML makes provision for this, and the UBO is deemed to be the natural person in real control. This means looking at the constitution, or articles of association, and determining what formal position holds control. We would then look for the minutes of the meeting that appointed or elected a natural person to that position, and there you have the person with significant control, or UBO.

This process is followed with variations through all the different types of organisations that exist, and are allowed to trade financially. But ultimately, there is always a beneficial owner, or person with control, and that person or persons will need to be determined, go through the identity verification process, and be checked against any watchlists for money laundering terrorism funding or as a PEP.  

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