Can you Keep a Secret? Publishing the Identity of Ultimate Beneficial Owners

Customer due diligence is a familiar phrase for many. But at a time when money laundering is estimated to represent between 2 – 5% of GDP globally , customer due diligence is set to change and the UK Government is at the forefront of developments.

Who are you?

Customer due diligence is a key stage in anti-money laundering procedures. However, identifying who a customer is can be difficult if the direct owner of a company is not necessarily the person who ultimately controls or benefits from it (the ultimate beneficial owner (“UBO”)). Opaque company structures are often used to disguise the UBO, sometimes for legitimate reasons of privacy but also to provide the secrecy needed for criminal activity.

In the wake of the Panama Papers and public outrage and political concerns around corporate transparency, the UK became the first G20 country to implement a public register of local companies’ beneficial owners  (the “PSC

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