Universal topic learning · Practical workbook

Ownership & Counterparty Review Workbook

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Use fictional details for practice. Real counterparty reviews follow requirements applicable to your role and the approved Compliance process.

Practise with fictional information. Use your approved procedures for real work.

Before you begin

• Confirm the legal entity and relationship purpose.
• Resolve differences between trading, contract and payment names.
• Trace ultimate natural-person ownership and control under the applicable definition.
• Record the evidence for each ownership link and any unresolved gap.
• Review relevant risk factors without treating a red flag as proof of guilt.
• Verify possible screening matches using approved identifiers.
• Escalate unresolved concerns and material payment or ownership changes.
• Keep the restricted decision trail and defined review triggers.

Your planning worksheet

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Practice scenario

Supplier A lists Holding B as its owner, but no evidence for Holding B is available. An urgent email then asks for payment to an unrelated account. Record the gaps and appropriate next steps.

Primary references

• FATF beneficial ownership resources
• FATF private-sector risk-based guidance

Project-authored exercises. References support the underlying principles; this workbook does not prescribe company procedures.