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Guidance on verification of the identity of Beneficial Owners

1. In determining whether an individual meets the definition of Beneficial Owners regard should be had to all the circumstances of the case, in particular the size of an individual's legal engagement or beneficial ownership in a Transaction.
2. For a retail investment fund that is widely-held and where the investors invest via pension contributions, the Regulator would not expect the manager of the fund to look through to any underlying investors where there are none with any material control or ownership of the fund. However, for a closely-held fund with a small number of investors, each having a large shareholding or other interest, the Regulator would expect a Relevant Person to identify and verify each of the Beneficial Owners, depending on the risks identified as part of its risk-based assessment of the customer. For a corporate health policy with defined benefits, however, the Regulator would not expect a Relevant Person to identify the Beneficial Owners.
Added on (15 April, 2019).