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Hossam M. Abd El-Rahman

Title Identification of Beneficial Owner
Add Date 13/10/2009
Sent By Phan Hoai Duong
Position Official
Area AML
Query Please let me know some measures for identification of beneficial owners of customers.
Answered By Hossam M. Abd El-Rahman
Answer Dear Phan,

Thanks for using ASK THE EXPERT Service, please find below the answer to your query:

To Identify the Ultimate beneficial owner for accounts, the Financial Institution needs to ensure that it properly knows their customers and knows who is having controlling powers over accounts: e.g. Power of attorneys, guarantors, guardians, trustees, ... etc.

At the time of initiating the relation with the customer, the Financial institution should be able to get such information if it designed its Customer Application form in a right manner. Down the line in the relationship, the Financial Institution should be able to capture such information through customer transactions monitoring and customer relations monitoring.

It is essential to open a customer file for those customers controlling the accounts, but are not account holders, this will enable the financial Institution to screen them against the blacklists and ensure that they are no listed, The Financial Institution will also be able to link them to the customers and accounts that they are operating on.

Regards,

Hossam Abd El-Rahman
Allied Compliance Consultants "ACC




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