Identifying Corporations & Beneficial Ownership (BO)

When the client is a corporation or entity, remember: the client is the corporation itself, not just the signing officer.

Step 1 – Identify the Corporation

Collect and record:

• Legal name of the entity
  
  

• Business Number (BN) from CRA
  
  

• Registered/legal address
  
  

• Type of entity (corporation, partnership, trust)
  
  

• Proof of registration (Articles of Incorporation or registry extract)
  
  

• Nature of business
  
  

📌 The ReallyTrusted Corporate ID form captures these automatically when you upload documents.

Step 2 – Verify Directors

• Obtain names of all current directors (usually found in registry documents or annual returns).
  
  

• Directors do not need to be ID’d unless they are also beneficial owners or authorized signing officers.
  
  

Step 3 – Determine Beneficial Ownership (BO)

• Beneficial owners = anyone who directly/indirectly owns or controls 25% or more of the corporation.
  For each beneficial owner:
  
  

• Full legal name
  
  

• Date of birth
  
  

• Address
  
  

• Occupation
  
  

• Ownership/control percentage
  
  

If no one meets the 25% threshold, record the most senior officer (e.g., CEO) as fallback.

Step 4 – Declaration of BO

• Use the ReallyTrusted form or internal BO declaration.
  
  

• Must be signed by an authorized signing officer.
  
  

• If beneficial owners exist: record names, percentages, and ID them.
  
  

• If no beneficial owner ≥25%: complete a negative confirmation and ID the senior managing officer.
  
  

Step 5 – Sanctions & PEP/HIO Screening

• Screen the corporation, beneficial owners, and senior officers through ReallyTrusted against sanctions lists and for PEP/HIO status.
  
  

• Any match = immediate escalation.
  
  

Step 6 – Ongoing Monitoring

• Reassess BO information at every new transaction.
  
  

• For medium/high-risk entities, continue monitoring for 5 years.
  
  

✅ Key Takeaways for Agents

• Always treat the corporation as the client.
  
  

• Beneficial Ownership (BO) is mandatory. If you can’t confirm it, escalate.
  
  

• The ReallyTrusted Corporate ID forms now guide you through these steps.
  
  

• Never skip — BO gaps are one of the biggest FATF focus areas.