You are required to understand the ownership and control structure of your client.
You must identify and take reasonable measures to verify who the Beneficial Owners (BO) and Ultimate Beneficial Owner (UBO) of your client are. Your method of verification should reflect your client risk assessment.
You must take reasonable measures to identify and verify the full names of the board of directors or equivalent management body. Your method of verification should reflect your client risk assessment.
You are required to report any material discrepancies in information held by Companies House found during your engagement with the client.
You should ensure that you have an appropriate understanding of your client and their business so that you can complete the below risk assessment and effectively monitor transactions.
Your client risk assessment must be reviewed for accuracy using a risk-based approach. A documented review must take place where you identify any material change to your client, and annually as a minimum.
If any individuals associated with the client ownership and control structure are identified as a PEP, Enhanced CDD must be conducted, and the client engagement must be approved by a senior manager.
Non face-to-face clients should be considered as a high-risk factor. Appropriate steps should be taken to address this risk and documented.
What should be understood about beneficial owners?
You must identify and take reasonable measures to verify who the Beneficial Owners (BO) and Ultimate Beneficial Owner (UBO) of your client are. Your method of verification should reflect your client risk assessment.
What must be done if a PEP is identified?
If any individuals associated with the client ownership and control structure are identified as a PEP, Enhanced CDD must be conducted, and the client engagement must be approved by a senior manager.
How often should the client risk assessment be reviewed?
A documented review must take place where you identify any material change to your client, and annually as a minimum.