A legal entity applies to open an account in a financial institution. The owners of the entity are 20 individuals with equal shareholding. Who should be identified as the Ultimate Beneficial Owner (UBO), per Financial Action Task Force (FATF) guidelines?
FATF guidelines require identifying UBOs as individuals owning more than 25% or, if no one meets that threshold, those who exercise control through other means. In this case, no shareholder owns more than 25%, so the UBO is identified based on control, typically the person(s) in senior management.
In regards to ongoing CDD, financial institutions should ensure:
Ongoing CDD should follow a risk-based approach, meaning higher-risk customers are reviewed more frequently, while lower-risk customers are reviewed at longer intervals, optimizing resources and maintaining compliance.
A politically exposed person (PEP) wants to open an account with a financial institution and provides no evidence for source of wealth.
Which procedure should the financial institution follow?
For PEPs, FATF requires enhanced due diligence, including verification of the source of wealth before onboarding. The account should only be opened after receiving and validating sufficient evidence.
During adverse media screening, a KYC analyst discovers a customer's beneficial owner is implicated in an article about a tax evasion scandal. Which is the best next step?
Adverse media findings should be verified for credibility and accuracy before taking action. Cross-referencing with another reliable source ensures the information is factual and not based on unverified or biased reporting.
During the regular periodic review of a high-risk client, a KYC analyst performs EDD checks and detects the presence of a politically exposed person. The KYC analyst should escalate this issue to the:
When a politically exposed person (PEP) is identified during enhanced due diligence, FATF requires that senior management approve the decision to continue or terminate the relationship due to the elevated financial crime risk.
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