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Guide to UBOs

 

Introduction

Under the UK Anti Money Laundering Regulations 2017, Marlo Technologies Limited (“MARLO”) is obliged to understand who is the Ultimate Beneficial Owner (UBO) of each corporate client.

This requirement applies to both new customers and existing clients and MARLO may require you to complete an updated version of the Prequalification form every 6 months or when our routine monitoring makes us aware of possible changes in the UBO structure.

What are UBOs

If you are an entity that exists as a legal person, such as a private limited company, public limited company, limited partnership, trusts, charities or other similar body then it likely that you will have one or more UBOs.

A UBO is an individual or individuals.

  • Owning a direct or indirect shareholding in the entity of 25% or more,
  • Exercising, directly or indirectly, 25% or more of the voting rights,
  • Beneficiary, directly or indirectly of 25% or more of the assets or income of the entity,
  • Controlling, directly or indirectly of 25% or more of the assets or income of the entity,
  • The person in effective control of the entity.

Effective control, as referred to above is exercised through any of the following

  • Holding the authority to appoint or dismiss the majority of the executive or management body,
  • Control of the majority of voting rights,
  • An otherwise controlling influence on the entity, The power to dispose of the assets of the entity.
Questionnaire

The following questions must be answered to identify the UBOs of your organisation. Please note that there may be more than one UBO.

  • Are there natural persons who are entitled to or have special control of 25% or more of the assets of the organisation?
  • Are there natural persons who are entitled to a share of 25% or more in the profits of the organisation?
  • Are there natural persons who can exercise 25% or more of the voting rights at the general meeting of the organisation?
  • Are there natural persons who have effective control of the organisation?

If you answered Yes to any of the questions, then please fill in the details of all UBOs on the Prequalification form, stating the %Share per UBO. If you answered all questions with No, it means there are no UBOs.

  • Are there natural persons who hold 25% or more of the shares in the legal entity either directly or through another legal entity?
  • Are there natural persons who are entitled to or have special control of 25% or more of the assets of the organisation?
  • Are there natural persons who are entitled to a share of 25% or more in the profits of the organisation?
  • Are there natural persons who can exercise 25% or more of the voting rights at the general meeting of the organisation?
  • Are there natural persons who have effective control of the organisation?

If you answered Yes to any of the questions, then please fill in the details of all UBOs on the Prequalification form, stating the %Share per UBO. If you answered all questions with No, it means there are no UBOs.

Documentation

You must provide Proof of Identity and Proof of Residency for every individual listed in the UBO section.

Proof of Identity

We currently accept scan of a valid passport for proof of identity.

Proof of Residency

We currently accept either a bank statement or a utility bill, dated within the last 3 months, for proof of residency. We do not accept mobile phone bills or landline bills.

Additional Documents

MARLO may also require additional documentary evidence to support the identification and verification of a UBO. This might include copies of share certificates, share registers, ownership or voting agreements, partnership agreements, declaration of trust or other evidence prepared by suitably qualified professionals.