A common theme from the Panama Papers in 2016, Paradise Papers in 2017 and Pandora Papers in 2021 is the challenges faced by financial institutions when attempting to ascertain ultimate beneficial owners and the potential misuse of complex corporate structures. As financial institutions continue to face enhanced public scrutiny and potential regulatory attention, it is important they allocate competent resources (both human and technological) to their anti-money laundering programs, evidencing the application of a robust risk-based approach to due diligence.

Whilst there is no “one-size-fits-all” approach to identifying ultimate beneficial owners, the detrimental impact on society and the ramifications of the reputational damage of failing to do so can be profound. Whilst there is no shortage of guidance issued by various regulatory bodies, the requirements to which financial institutions and other organisations should adhere is worth highlighting. Therefore, a recently published article by the International Compliance Association demonstrates a range of options how to do so.