Beneficial ownership disclosure workbook

Scenario B


Persons 1, 2 and 3 have an indirect relationship with the declaring company: there are a number of intermediate entities.

Company A is registered in the same jurisdiction as the declaring company and directly holds 60% of its shares. Person 1 has a 25% stake in Company A. The other 40% of the declaring company's shares are held by Company B which is a UK-registered public limited company with shares trading on a regulated UK market.

Via a further, domestically-registered company (Company C), Person 1 owns 20% of the stock of Company B. A further 25% of Company B's stock was owned by Person 1 but is now settled in a trust arrangement, under local law. The trustee of the arrangement is Person 2. Person 3 is the beneficiary of the Trust. The details of the trust arrangement are confidential.

Via their holdings in Companies A and C, Person 1 has 23% of the declaring company's shares. Person 2 controls a 10% stake in the declaring company, for the benefit of Person 3.

Points for consideration

  • Which of the individuals (Person 1, Person 2, Person 3) should be declared as beneficial owners of the declaring company, under domestic requirements?
  • Do any of those individuals have a legal responsibility to notify the declaring company of their beneficial ownership.
  • If an individual were declared as a beneficial owner, how much information would be disclosed about intermediary companies and relationships?
  • If Person 3 were a relative of Person 1 would this affect what is declared?
  • If Person 1 were the settlor and beneficiary of the trust, would this affect what is declared?

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