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US Beneficial Ownership Rule Could Drive Use of Complex Corporate Structures

By Daniel Bethencourt

Many compliance officers may have never heard of "circular ownership," a corporate structure of holding companies and subsidiaries that financial institutions often struggle to map out and unravel during the customer-onboarding process. Despite its relative obscurity, analysts speculate that the arrangement is uniquely positioned to bypass onerous, pending customer due-diligence requirements and beneficial-ownership checks which, alongside increasingly complex sanctions rules, have demanded the lion's share of attention from U.S.-based anti-money laundering personnel. "I think it's not on anyone's radar," Fred Curry, principal in the regulatory and compliance practice of Deloitte Transactions & Business Analytics, said. "This is a newer structure...

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