Free Acams CKYCA Actual Exam Questions - Question 10 Discussion
individuals with equal shareholding. Who should be identified as the Ultimate Beneficial Owner
(UBO), per Financial Action Task Force (FATF) guidelines?
D The FATF guidance says if no one owns over 25%, you look for people who exercise control or are senior management. So even if it’s not clear, D fits better than just naming all shareholders.
Option D makes sense because when no one owns over 25%, FATF says to identify those who actually control or manage the entity, not just shareholders. So senior management or controllers matter here.
D imo. Since none of the shareholders exceed 25%, it makes sense to look at who actually controls the entity in practice. FATF guidelines do emphasize control through senior management or other means beyond just ownership percentages. Unless there’s evidence of a voting pact or shared control, the key is who’s really running the show day-to-day. So if senior management exercises control, they would be the UBOs here rather than just shareholders with small stakes. This fits better than picking multiple shareholders or saying no UBO exists.
Option B seems right here since none of the shareholders individually cross the 25% threshold, so FATF would consider all 20 as UBOs. Option D relies heavily on control or senior management info, which we don’t have. Without evidence that someone else controls the entity, you can’t just assume management are UBOs. Also, option A doesn’t make sense because picking any six shareholders to exceed 25% isn’t a thing, and C is clearly wrong since there are actual owners. So sticking with all owners as UBOs fits FATF’s transparency goal.
B all the way, no one crosses 25%, so everyone counts as UBO.
It’s B for me. Since no single shareholder or group passes the 25% mark, FATF says you list all the owners as UBOs. D might be tempting if we had details on who actually calls the shots day-to-day, but that info isn’t given here. So, the safest bet is to identify all 20 shareholders as UBOs because they all have equal ownership and none hits the usual threshold alone.
B. If no one passes 25%, all shareholders count as UBOs per FATF rules.
Isn’t the key here who actually controls the company, not just shareholding? How do we know if any senior management has control beyond just owning shares?