The term ‘Ultimate Beneficial Ownership’ reflects a recognition that a person in whose name an account is held is not necessarily the person who ultimately controls such funds. This distinction is important because the focus of AML compliance efforts needs to be on the person who has this ultimate level of control. Placing the emphasis on this person is typically a necessary step in determining the source of wealth.
The source of funding paid into an organization’s account does not necessarily mean that it is clean. The correspondent bank may well have put in a report and received consent to send it to you, while law enforcement watches how the funds are being used and gathers more evidence.
Organizations need to make their own decision about the consistency of the funds with the counterparty and whether there is information on which you can form a suspicion of money laundering or not. Appreciate that no one expects you to be ‘police officers’ investigating potential crimes; rather you are taking steps to protect your firm from being used to launder funds.
In order to protect your organization from enforcement action and reputational damage, it is vital that you understand the source of wealth of those with whom you do business. If your clients or counterparties have derived funds from illegitimate means, including bribery, fraud or money laundering, there could be severe consequences. Sophisticated criminals are adept at concealing the source of illegitimate funds and tracking the exact source is not always straightforward.
Organizations around the world choose Thomson Reuters to help mitigate their risk and safeguard their reputation. We offer:
Accelus Enhanced Due Diligence (IntegraScreen): a structured approach to identification and checking UBO of important third parties ensuring up to date and auditable compliance
Accelus World-Check: finding hidden UBO risk in business relationships and extended partner networks by screening customers against comprehensive KYC risk intelligence data
The due diligence on preexisting entity account held by prima facie FFI must be completed on December 31, 2014. New account due diligence procedures must also be in place to establish the FATCA (Foreign Account Tax Compliance Act) status of new entity accounts.
A prima facie FFI is an entity that is a qualified intermediary (QI) or non-qualified intermediary (NQI) or a foreign entity that has a North American Industry Classification System or Standard Industrial Classification code that indicates that it is a financial institution.
How ready are you for FATCA due diligence for FFI relationship?
How can Thomson Reuters FATCA help you?
Thomson Reuters Identity simplifies and accelerates the tax documentation process. It facilitates the collections, validation and maintenance of all W-8 and W-9 Forms and any other agreed FATCA self-certification documentation online. Identity facilitate in declaring Chapter 4 status.
Identity for FATCA can help you in the following:
Tax document service to collect and maintain W-9, W-8 series and self-certification forms online
Creates a quicker process for obtaining documentation, keeping it up-to-date and reporting
Assists users in detecting people who are subject to U.S. Taxation
Enables the management of complex entity structures by linking entities with beneficial owners.
Coming up next will be Reporting dateline to be phase in from March 2015, how prepared are you?
Climb to the Top – Tracking gender diversity on corporate boards
Gender diversity on boards has been the subject of study for some time, and by a wide variety of organizations and methodologies. Nearly all the research shows that while there are more women on boards each year, progress is slow. Hoping to provide some objective and comprehensive data around the topic from Thomson Reuters own data and analytical capabilities, as well as to spur further dialogue, we undertook analysis of 4,255 public companies around the globe.
This paper reports on levels of board gender diversity for 4,255 companies around the world by industry and region; diversity policies and processes; and returns comparisons for the past five fiscal years. Read the full report to find out more.