Beneficial Ownership - Why the Devil Really is in the Detail

Tuesday, April 4 | 3:05 PM

Speaker:

Melaine B. Campbell, Esq., Managing Director, Dun & Bradstreet

Thomas Cosgrove, Strategy Leader, Compliance, Dun & Bradstreet

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Why is Beneficial Ownership (UBO)

so important to buyers today?

Fundamental regulatory requirement, but rules not consistent

Need to access people data in context of businesses

Illustrates good corporate governance

W H A T I S N E E D E D :

Quick access to reliable and consistent global data

Effective calculations of complex ownership to reduce time and effort

Real-time data updates for insights and action

Automated processes to accelerate due diligence process

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Hidden Ownership

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Defining Reasonable Measures

Adopt a combination of the

best available mechanisms

Include self-certification,

integrating or cross

referencing with registry

data or a reputable partner’s

Beneficial Ownership

database

Exhaust all

reasonable measures

to identify and verify

Beneficial Ownership

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A data inspired approach to

understanding ownership

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Beneficial Ownership

DIRECT UBO INDIRECT UBO

An Ultimate Beneficial Owner is a ‘Natural Person’ who directly / indirectly

has control of the business and gains financial benefit

They can either directly or indirectly have ownership of a business.

P1 is a ‘Direct’ owner of company 1

and owns 30% shareholding

P2 is an ‘Indirect’ owner of company 1

and owns 70% shareholding

(calculated based on them owning 100% of company 2

which owns only 70% of company 1)

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Simple Indirect Shareholding

AAABBB Ltd (DUNS:123456789)

Indirect Owners

Individual

Corporate

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Multilevel Indirect Shareholding

Individual

Corporate

Target XXX GmbH

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Multilevel Indirect Shareholding

In most programs P1 @ 1% will not be considered

C1 (target is 100% owned by C1)

P1 is the UBO

P1

C1 C2

1%

100%

99%

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Indirect Shareholding with Multiple Loops

A Russian Company

Individual

Corporate

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D & B A P P RO A C H

Here is Our “Full Structure” Call for a UK Business

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CONSIDERATIONS

Simplified direct or indirect

ownership should be AUTOMATED

as part of workflow

Consider ‘change in instance’

ALERTING

Understand YOUR PATHS from a

target entity to their UBO & CBO

Recognize LOOPING relationships

Calculate percentage of ownership

for each entity within a structure

and provide for ‘UNKNOWN’

entities for when the tier does not

meet 100% ownership

Consider agreed POLICY positions

on different entity types

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Data Accuracy and Granularity -hierarchy data that includes corporate entities and individuals

Data Freshness

Data Coverage

Data Security

Legitimacy, Consistency and Reliability

Stability

Integrity

Available through Batch, API and Online

Calculate Beneficial Owners on the fly

Utilize enhanced and normalized data for accuracy and consistency

Third-Party Data Provider Checklist

Beneficial Ownership Data and Analytics

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B e n e f i c i a l O w n e r s h i p D i r e c t f o r C o m p l i a n c e A P I s

Calculate beneficial owners on the fly

Utilize enhanced and normalized data for

accuracy and consistency

Available via Direct for Compliance with

two API calls: full structure (all

associations with the business), list of

beneficiaries (corporates or people)

Offer “one up” linkage data that includes

corporate entities and individuals

Available through Batch, API, and Online

Maintained and held “as registered” data

to ensure proper like-for-like reporting

Beneficial Ownership Data and Analytics: Our Offering

6 2 C O U N T R I E S C O V E R E D 4 6 M T A R G E T D - U - N - S 7 0 M S H A R E H O L D E R S

( 6 3 M I N D I V I D U A L S , 7 M C O R P O R A T E S )

AVA I L A B L E O N L I N E V I A O N B O A R D / T H R O U G H B AT C H D E L I V E RY

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Consider asking yourself these questions:

• Are we taking all reasonable measures to mitigate the risk by leveraging

global data that is accurate, reliable, timely, robust and verifiable?

• Does our data bring together corporate linkage and share ownership?

• Can we get to this data quickly through modern delivery channels?

• Can we leverage analytics to understand direct and indirect relationships,

handle looping control and support all end points?

KEY TAKEAWAYS

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B E N E F I C I A L O W N E R S H I P

Protection. Speed. Efficiency.

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