Beneficial Ownership Amendments Understanding
The Cascading Test
Step 1: Primary method is
to first identify all
individuals who ultimately
have a controlling
ownership interest (25% or
more) in the company,
either directly (in their own
names) or indirectly
(through a chain of other
entities or arrangements).
Ultimate Ownership
Step 2: Where there is doubt
as to whether the persons
with the controlling ownership
interest are the beneficial
owners, or where no natural
person exerts control through
ownership interests then,
the beneficial owner shall be
the natural persons (if any)
exercising control of the legal
person through other means.
Ultimate Effective Control
Step 3: Where no natural
person is identified under the
previous steps, companies
should identify and take
reasonable measures to verify
the identity of the relevant
natural person who holds the
position of senior managing
official
Highest management
AuthorityView entire presentation