What needs to be clarified
Compare the questionnaire, corporate records and update log to map the documented ownership chain and identify specific gaps in establishing the person with ultimate control.
Materials to prepare
- Client questionnaire and ownership chart with preparation and update dates
- Registry extracts and documents recording changes in company members
- Internal control rules and log of requests for further information
What to compare
Check document effective dates, ownership percentages, intermediary entities and control exercised other than through direct ownership. Record the source and currency of each link. Compare changes with the file update procedure and document unresolved contradictions without filling gaps with assumptions.
Possible outcome of the analysis
A report may provide an auditable relationship chart, missing supporting documents and proposed file updates; its conclusions depend on the completeness and consistency of the records.
Limits of the conclusions
The review does not establish criminal origins of funds or guarantee a bank's decision. Applicable duties require separate checks by jurisdiction, activity and transaction date.