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How do you confirm the accuracy of beneficial ownership information?

To confirm the accuracy of beneficial ownership and information on the ownership, control and structure of an organization you should refer to official documentation or records, such as:

  • minute book
  • securities register
  • shareholder register
  • articles of incorporation
  • annual returns
  • certificate of corporate status
  • shareholder agreements
  • partnership agreements
  • board of director’s meeting records of decisions

It is possible for one document to be used to satisfy the two distinct steps, namely, to obtain the information and to confirm the accuracy of it.

You may also have the client sign an attestation to confirm the veracity of the beneficial ownership information provided. This document must include the ownership, control and structure information obtained.

Other reasonable measures to confirm accuracy include:

  • asking the client to provide supporting official documentation
  • consulting an online registry where available
  • conducting an open-source search
  • consulting commercially available information