Firms should resort to identifying the customer’s senior managing officials as beneficial owners only if:

a) They have exhausted all possible means of identifying the natural person who ultimately owns or controls the customer;

b) Their inability to identify the natural person who ultimately owns or controls the customer does not give rise to suspicions of ML/TF; and

c) They are satisfied that the reason given by the customer as to why the natural person who ultimately owns or controls the customer cannot be identified is plausible.