Leela
KYC / CIP / KYB
KC-03

Identify, verify, and screen beneficial owners

Policy reference

KYC / CIP / KYB policy, §4

Bank Secrecy Act regulations, beneficial ownership requirements for legal entity customers, 31 CFR 1010.230
Requirement

For each legal-entity customer, every natural person owning 25 percent or more and one control person is certified by the customer, verified by document and database checks, and screened against sanctions and adverse media, looking through intermediate entities until natural persons are found.

Trigger

Event-driven

Each legal-entity customer, before account activation

Action

Obtain the signed beneficial ownership certification, verify each owner and control person, screen them, and escalate any structure that cannot be resolved.

Evidence
  • Beneficial ownership certification

    Signed form with each owner and percentage

  • Owner verification and screening results

    Per person, with disposition

Owner

Operations

Leela can
Prepare for review

Leela can prepare the artifact and hand it to a person for review.

Leela can prepare the certification packet and the verification checklist for each owner.

Applies

Tell Leela about your company to see whether this applies.

Status
Setup needed

Tell Leela how you handle it today, or hand it over: see what’s next.

What’s next?