We are finally reaching the end of the road on the beneficial ownership path. In this last posting on the issue (for now), let’s start with a third-party population (third parties, vendors, suppliers) which have been classified into three categories, the first two of which fall into high-risk (foreign government interaction/representation and government ownership). The bulk of the population, usually around 80 to 85 percent...
When discussing the importance of beneficial ownership with compliance professionals, there is often a disconnect between the theory and reality. Everyone understands the legal and compliance risks and how they apply to third-parties, vendors and suppliers. But when a compliance officer considers the burden of uncovering beneficial ownership interests, they quickly resist the need for such an analyses across the population. And for good reason....
We repeatedly hear about the importance of beneficial ownership, and the requirement that companies confirm beneficial ownership of its third-parties, vendors and suppliers. At the same time, there is increasing pressure from regulators and law enforcement to identify and unravel beneficial ownership when dealing with business partners. There is no question that beneficial ownership is a critical issue. I have frequently stated (i.e. repeated myself)...
