Distinguish ownership-prong and control-prong beneficial ownership review.
The reframe: Ownership percentage is only one route to control. Ownership prong Start with direct and indirect equity. Layered entities require multiplication and aggregation, not just reading the cap table's first layer. Watch for split holdings that appear designed to stay below a threshold. Control prong Every legal entity has someone with significant responsibility to direct it. That person may be an executive, manager, trustee, partner, or other controller. If the person signing instructions is missing from the ownership chart, do not ignore the gap. Evidence quality A certificate is useful, but FATF's multi-pronged logic is stronger: combine customer-provided information,…
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