Performing UBO screening involves several general steps:
Step 1: Obtain the Entity’s Identity and Credentials
Gather comprehensive and up-to-date information about the company, including registration number, name, address, legal status, and key management personnel. Specific requirements may vary depending on jurisdiction and fraud regulations.
Step 2: Research the Ownership Chain
Identify natural or legal persons with ownership stakes or interests and determine whether the ownership is direct or indirect.
Step 3: Identify the Ultimate Beneficiary
Determine the UBO by assessing the ownership interest or management control, including the total percentage of shares and ownership stake, and verify if it falls under UBO regulations in the UAE.
Step 4: Perform an AML/KYC Check
Subject all identified UBOs to a comprehensive Anti-Money Laundering (AML) and Know Your Customer (KYC) check.
Screen the UBO for potential risks, such as inclusion in Politically Exposed Persons (PEP) lists, inspection lists, sanction lists, or negative publicity.
Step 5: Prepare a Risk Assessment
Categorize UBOs into risk levels, ranging from low to high, and adopt appropriate risk mitigation measures:
Low Risk: UBOs can confirm their identity by signing a statement and undergo visual checks against identification documents.
Mid to High Risk: For PEPs or cases related to terrorism or money laundering, conduct thorough investigations, including:
Additional searches to gather information about the customer’s risk profile, including political exposure, adverse media coverage, and legal enforcement actions.
Analysis of the individual’s source of wealth and funds, noting any discrepancies.
Collect information about the purpose and nature of the business relationship.
Provide annual updates on substantial ownership changes.