FTAF is consulting on updates to its guidance on Recommendation 24, following the amendments to the Recommendation that it adopted in March.
The draft guidance explains the purpose of gathering beneficial ownership information, and notes that the revisions to the Recommendation explicitly require countries to use a multi-pronged approach to collecting the information to ensure that information that is adequate and up to date can be accessed in a timely manner both by the authorities and sometimes by entities subject to CDD obligations. The changes also require countries to apply a risk-based approach to legal persons operating in their jurisdictions. The guidance looks at the factors that should be considered and how results of risk assessments should be shared. It goes on to explain the recommendations for how companies registries should operate and make information available. While noting that countries may set their own ownership thresholds when requiring disclosure of beneficial ownership information, it says this should not be more than 25%. It also gives examples of ways through which beneficial ownership may be held other than through shareholdings. It moves on to look at verification measures before looking at ways of keeping and accessing the information, and recommending what sanctions should be imposed for non-compliance.
Consultation closes on 6 December.