The FCA's 2019 Standard Chartered notice put a number on a quiet operating truth. The bank was fined £102.2 million in part because branches in higher-risk jurisdictions failed to adequately establish ...
Tackling sanctions evasion can often be likened to patching a leaky boat. As one hole is patched, another opens. This is particularly the case when dealing with kleptocrats. Kleptocracy is when ...
Multi-tiered entities (MTEs) offer businesses a sophisticated organizational structure with multiple layers of ownership and control. But the complex ownership structures and intercompany ...
The Central Bank of Nigeria recently issued a circular requiring fintechs and other regulated financial institutions to identify, verify, and disclose their Ultimate Beneficial Owners (UBOs).