Anti-Money Laundering Principles for Private Banking | Beneficial Owners

Ordinarily Beneficial Owners of Private Banking Accounts | CAMS Exam

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Question

Which two individuals are ordinarily beneficial owners of a private banking account according to the Wolfsberg Anti-Money Laundering Principles for Private

Banking? (Choose two.)

Answers

Explanations

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A. B. C. D.

CD

https://www.wolfsberg-principles.com/sites/default/files/wb/pdfs/wolfsberg-standards/10.%20Wolfsberg-Private-Banking-Prinicples-May-2012.pdf

(2)

According to the Wolfsberg Anti-Money Laundering Principles for Private Banking, the two individuals who are ordinarily considered as beneficial owners of a private banking account are:

B. Those who have legal title to a controlling share interest in the customer: This refers to individuals who hold legal title to the shares of a customer that owns the account. Such individuals are deemed beneficial owners because they have a controlling interest in the customer and, by extension, in the account. They may have the power to direct the customer's financial activities, including the use of the funds in the account, and may benefit from any profits or losses arising from such activities.

C. Those who generally have ultimate control through ownership or other means over the funds in the account: This refers to individuals who have ultimate control over the funds in the account, regardless of whether they hold legal title to the customer or shares in the customer. Such individuals may include beneficial owners who exercise control over the customer through other means, such as through a trust or nominee arrangement, or through their ability to direct the customer's financial activities. These individuals may benefit from the use of the funds in the account or may have the power to direct the use of such funds.

The other options, A and D, do not necessarily represent beneficial owners according to the Wolfsberg Principles. Authorized signers on an account (option A) may have the power to transact on the account but do not necessarily have an ownership interest or control over the funds in the account. Similarly, the ultimate source of funds for an account (option D) may not necessarily be a beneficial owner if they do not have legal title to the customer or control over the funds in the account. However, identifying the ultimate source of funds is important in conducting customer due diligence and assessing potential money laundering risks.