Apply ownership and control thresholds to identify ultimate beneficial owners in corporate and trust structures.
Finance & Banking
Identifying Beneficial Owners Behind Trusts, Nominees and Layered Companies
Trains onboarding and AML teams to unpick trust, nominee and multi-layer corporate structures, apply ownership and control tests, and document beneficial ownership to a standard that satisfies both onboarding and examiners.
🗓️Duration5 training days
📚Content4 modules · 8 sessions
🎓On completionAccredited attendance certificate
About the programme
Course Overview
A company registered only last week can already sit at the end of a chain of holding vehicles, nominee directors and a discretionary trust that has controlled an account for years. Untangling who actually owns and controls that structure is one of the hardest tasks in customer due diligence, and getting it wrong lets sanctioned individuals, corrupt officials and criminal proceeds hide behind a legitimate-looking corporate wrapper. This course sets out the ownership and control tests behind the Financial Action Task Force standards, works through how settlors, trustees, protectors and beneficiaries interact inside trust deeds, and shows how bearer shares, nominee arrangements and multi-jurisdictional layering are used to obscure control. Participants trace real ownership chains using corporate registry extracts, trust documentation and source of wealth evidence, decide when enhanced due diligence and senior sign-off are required, and practise documenting a beneficial ownership file that satisfies both the account opening team and a later regulatory examination.
Expected Learning Outcomes
Interpret trust deeds to map the roles of settlors, trustees, protectors and beneficiaries.
Trace layered and multi-jurisdictional ownership chains using registry extracts and corporate filings.
Recognise nominee shareholder, nominee director and bearer share arrangements used to obscure control.
Determine when enhanced due diligence, source of wealth verification and senior approval are required.
Evaluate politically exposed person and sanctions exposure within complex ownership structures.
Compile a beneficial ownership file that documents the reasoning behind each ownership determination.
Who Should Attend
Onboarding and client due diligence analysts in banks, fund administrators and corporate service providers.
AML compliance officers reviewing complex corporate and trust structures.
Relationship managers handling high-net-worth and corporate trust clients.
Company secretarial and trust administration staff processing ownership disclosures.
Financial crime investigators assessing shell company and layering typologies.
Correspondent banking teams assessing respondent bank ownership transparency.
Course Modules
Select any module to see its sessions and points.
01Ownership and Control Standards for Beneficial Ownership
2 sessions · 8 points
Session 1Ownership and Control Tests Under FATF Standards
- Apply percentage-based ownership thresholds and control tests to identify natural person beneficial owners.
- Distinguish legal ownership from ultimate control when a structure has no clear majority shareholder.
- Compare beneficial ownership definitions across FATF recommendations and national registry regimes.
- Assess senior managing official fallback provisions when no natural person can be identified.
Session 2Corporate Registries and Public Disclosure Sources
- Extract and verify ownership information from public and central beneficial ownership registers.
- Cross-reference company filings, shareholder agreements and annual returns for consistency.
- Identify discrepancies between self-declared ownership and independent registry evidence.
- Assess the reliability of beneficial ownership data across jurisdictions with weaker registry standards.
02Trusts, Nominees and Layered Corporate Vehicles
2 sessions · 8 points
Session 1Trust Structures and Fiduciary Roles
- Map the roles and powers of settlors, trustees, protectors and beneficiaries within a trust deed.
- Assess discretionary, fixed interest and purpose trusts for beneficial ownership implications.
- Identify letters of wishes and side arrangements that reveal true settlor influence over a trust.
- Evaluate foundation structures used in civil law jurisdictions as trust equivalents.
Session 2Nominees, Bearer Shares and Layering Techniques
- Recognise nominee shareholder and nominee director arrangements and the disclosures they require.
- Assess residual bearer share risk in jurisdictions that have not fully immobilised bearer instruments.
- Trace multi-jurisdictional layering structures designed to separate legal ownership from control.
- Identify circular ownership and shell company chains used to frustrate look-through analysis.
03Source of Wealth, Source of Funds and Enhanced Due Diligence
2 sessions · 8 points
Session 1Building the Source of Wealth and Source of Funds Picture
- Distinguish source of wealth from source of funds evidence and the documents that support each.
- Reconcile disclosed wealth narratives against corporate, tax and property records.
- Assess plausibility of wealth accumulation against career history, business activity and jurisdiction.
- Identify gaps and inconsistencies that justify further client enquiry before onboarding.
Session 2Escalation, PEP and Sanctions Considerations
- Determine triggers for enhanced due diligence and senior management or committee approval.
- Screen beneficial owners and connected parties against politically exposed person and sanctions lists.
- Assess adverse media and litigation history connected to identified beneficial owners.
- Decide when to decline, exit or restrict a relationship based on unresolved ownership risk.
04Documentation, Governance and Ongoing Monitoring
2 sessions · 8 points
Session 1Documenting the Beneficial Ownership File
- Compile an ownership chart and supporting evidence file that withstands independent quality review.
- Record the rationale behind each ownership determination, including assumptions and residual risk.
- Prepare files for internal audit, regulatory examination and correspondent bank scrutiny.
- Apply consistent file standards across onboarding teams and jurisdictions.
Session 2Ongoing Monitoring and Structural Change
- Design triggers for refreshing beneficial ownership data after corporate or trust structure changes.
- Monitor for undisclosed changes in control, directorship or trustee appointments over the relationship life.
- Coordinate periodic review cycles between onboarding, relationship management and compliance teams.
- Update beneficial ownership records following mergers, restructurings or change of registered agent.
What the participant receives
4 course modules
A structured syllabus
8 training sessions
across 5 days
32 detailed points
Applied, detailed content
Accredited attendance certificate
On completing the programme
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