Why the DNA of beneficial owners prevent companies from self-submitting beneficial ownership information

Anders A. L. Rodenberg

Journal of Financial Compliance, 2017, vol. 1, issue 2, 123-136

Abstract: The paper is a detailed analysis of beneficial ownership information and how best to obtain the information. The paper will provide readers with insights into a range of areas such as: ●● the data-DNA of beneficial owners; ●● the ‘three inherent flaws’ of asking companies to self-submit beneficial owner information; ●● how current political solutions to provide ownership transparency are built on an eroded data foundation leading to a false sense of security; ●● five key factors to obtaining correct beneficial owner information and ●● how anti-money laundering (AML) policies focusing on primary sourced beneficial ownership information leads to less rather than more AMLcompliance at financial institutions. The paper starts by taking a thorough look at beneficial owners from a data perspective by outlining the key beneficial ownership challenges and establishing why beneficial ownership is a radically different data point from others in the know your customer process. The next part considers some of the recent proposed political solutions to these challenges such as, for example, beneficial owner registries and problematises certain aspects of these solutions. The final section focuses on actual solutions to obtain beneficial ownership information, both in the perfect world and within the current political context.

Keywords: beneficial owner; beneficial owner registries; anti-money laundering (AML); sanctions; compliance; FinCEN customer due diligence (CDD) rule (search for similar items in EconPapers)
JEL-codes: E5 G2 K2 (search for similar items in EconPapers)
Date: 2017
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Persistent link: https://EconPapers.repec.org/RePEc:aza:jfc000:y:2017:v:1:i:2:p:123-136

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