Increased beneficial ownership (BO) scrutiny is compelling organizations across industries to adapt compliance practices to satisfy several laws and regulations that include Know Your Customer (KYC), Anti-Money Laundering (AML), and the Foreign Account Tax Compliance Act (FATCA). Establishing a comprehensive beneficial ownership management program is crucial; beneficial ownership and ultimate beneficial ownership (UBO) identification and verification have become an essential component of the onboarding process for clients, customers, partners, and vendors.
Implementing an effective BO program can be a challenge, since BO definitions and due diligence requirements can vary depending on the regulation. The collection process itself can be a burden, made tougher by the lack of publicly available UBO registry data. Nevertheless, compliance professionals should take all reasonable measures to mitigate the risk associated with beneficial ownership information.
So how can companies establish effective BO collection, identification, and verification procedures to meet the relatively new laws? One way is by performing a separate audit project to manage the changes, and evaluating the integrity and effectiveness of the compliance program with BO -related regulatory obligations. However, there isn’t a one-size-fits-all fix; each company should take an approach that is commensurate with their risk profile.
This white paper will delve into how many organizations address how enterprise-wide risk assessment should be revisited, from an auditor’s perspective. It also explores which best practices are needed to establish a robust beneficial ownership management program.