On Dec. 1, BNG CB issued guidance on bank UBO identification.
BNG CB issued circular on identifying and reporting ultimate beneficial owners (UBOs) of banks, aiming to bring enhanced transparency to bank ownership structures.
Transparency Requirements
Defines UBO as natural persons who directly/indirectly own or control >2% shares.
Banks must maintain database of UBO data, report quarterly starting Mar. 31, 2025.
Quarterly report must use prescribed format and include pertinent details as specified.
Any ownership changes must be reported immediately upon being made aware of it.
Banks must identify UBOs through direct/indirect shareholding calculations, control through other means like management influence or voting rights, along with senior management identification only as last resort after exhausting other methods.
Documentation must include identity verification of UBOs, verification of UBO status and their respective control rights, as well as relevant ownership structure maps.
BNG GVT entities, state-owned enterprises, international financial institutions exempt.
Effectiveness
The first data set must be submitted to BNG CB by Mar. 31, 2025.
Regulators
BNG CB
Entity Types
Bank
Reference
Cir 16/2024, Form, 12/1/2024
Functions
Compliance; C-Suite; Legal; Operations; Record Retention; Reporting; Risk
