Beneficial ownership charts that survive verification
Intermediate layers, nominee arrangements, and the exhibit set we expect when testing ownership during KYC audits.
Beneficial ownership is where many KYC packs look complete until an auditor asks for the layer above the direct shareholder. During verification we compare the chart in the file with company registry extracts, trust deeds, and board resolutions that authorised the relationship.
Intermediate companies
If Customer A is owned by B Ltd, which is owned by C Ltd, the file needs evidence for each layer down to the natural persons who meet the firm’s threshold. Stopping at B Ltd because “it is regulated elsewhere” still produces findings when your own procedures require look-through.
Nominees and trustees
Nominee declarations help, but they are not a substitute for identifying the person who ultimately owns or controls. Where a trust sits in the chain, we look for trustee details and the class of beneficiaries your policy treats as relevant.
Keeping charts current
Ownership changes after onboarding often lag in the CDD file. Periodic review checklists that only tick “no change confirmed by relationship manager” without refreshed registry pulls are a recurring theme in our financial auditing fieldwork.