Due Diligence and Ongoing Monitoring

How many organizations collect beneficial ownership information in the Inherent Risk Assessment/Intake Form when onboarding a vendor?

Please see portion of the Interagency Guidance below.

This may include (1) evaluating the third party's ownership structure (including identifying any beneficial ownership, whether public or private, foreign, or domestic ownership).

I've been reading this and had questions if others collected the information or not. 

Hi William,

For the benefit of other members, I thought I would explain what a beneficial owner is and why they matter. A beneficial owner is an individual who may own or control a company or asset, even if the company or asset is held under another legal name. Beneficial owners have significant influence or control over the company, usually by owning a large portion of shares or voting rights. So, they naturally benefit financially from the entity's activities. It is essential to identify beneficial owners to ensure transparency and to ensure compliance with tax and AML laws.  Regulatory guidance, such as the Interagency Guidance on Third-party Relationships, requires the disclosure of beneficial owners to ensure adherence to anti-money laundering (AML) and counter-terrorism financing (CTF) laws.

For these reasons, it is recommended that you require your third parties to disclose beneficial owners and include them in your OFAC and PEP searches as part of due diligence. Even though this is a best practice, I would also like to know if other members are collecting and researching this information.

How many organizations collect beneficial ownership information in the Inherent Risk Assessment/Intake Form when onboarding a vendor?

Please see portion of the Interagency Guidance below.

This may include (1) evaluating the third party's ownership structure (including identifying any beneficial ownership, whether public or private, foreign, or domestic ownership).

I've been reading this and had questions if others collected the information or not.