For customers that are legal persons, Licensees must identify and take reasonable measures to verify the identity of beneficial owners through the following information:

(a) The identity of the natural person(s) who ultimately have a controlling ownership interest in a legal person, and
(b) To the extent that there is doubt under (a) as to whether the person(s) with the controlling ownership interest is the beneficial owner(s), or where no natural person exerts control of the legal person or arrangement through other means; and
(c) Where no natural person is identified under (a) or (b) above, the identity of the relevant natural person who holds the position of senior managing official.
Added: October 2017