A common theme from the Panama Papers in 2016, Paradise Papers in 2017, and Pandora Papers in 2021 is the challenges faced by financial institutions when attempting to ascertain ultimate beneficial owners (UBOs) and the potential misuse of complex corporate structures.
As financial institutions continue to face enhanced public scrutiny and potential regulatory attention, it is important they allocate competent resources (both human and technological) to their anti-money laundering (AML) programs, evidencing the application of a robust risk-based approach to due diligence.
