A company is owned by a parent company in a large group. Following attempts the company has been unable to determine who the beneficial owner is. On this basis who is included as the beneficial owner in the beneficial ownership register?

The beneficial ownership rules state where the beneficial owner cannot be determined then the Company’s Senior management are to be included as the beneficial owners in the beneficial ownership register. It is all of the senior management, one person on the senior management team cannot just be nominated. The European Union (Anti-Money Laundering: Beneficial Ownership of Corporate Entities) Regulations 2016 refers.