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What are “reasonable efforts” with respect to identifying beneficial owners?

The reasonable efforts standard requires you to apply sound, sensible judgment about the measures you take to identify beneficial owners. Reasonable efforts include searching through as many levels of information as necessary to identify those individuals. In making reasonable efforts to determine beneficial ownership, it is important to understand that the names on legal documentation may not be the actual owners of an organization. You must assess and determine what is appropriate for each situation to ensure the accuracy of the information obtained, while also taking into account the risk associated.