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对于在受监管环境中处理KYB的机构，特别是金融科技平台或经纪商在引入本身受监管的非美国实体（例如，欧盟授权的投资公司或英国支付机构）时，对于受益所有权尽职调查的深度，普遍的共识是什么？除了标准的公司文件和制裁检查外，一份在职证明和一份来自其本国监管机构的良好信誉函是否足够？或者公司是否会进行更深入的调查，即使该实体是上市公司或受监管实体，也要识别每一个最终受益人？
Interesting point. For regulated non-US entities, I've seen varying approaches. Some platforms do a deep dive into beneficial ownership, similar to an unregulated entity, while others rely more on the entity's own regulatory oversight and good standing certificates. It often depends on the risk assessment framework of the onboarding institution.
That's a good question and often depends on your internal risk framework and the specific regulations you're subject to. For regulated non-US entities, we typically start with public registry checks and their regulatory license status, then follow up with incumbency certificates and good standing letters. However, we also conduct a more in-depth UBO check beyond a certain ownership threshold, particularly if the entity is from a higher-risk jurisdiction.
The level of detail for beneficial ownership on regulated non-US entities often depends on the specific regulatory framework you're operating under, as well as the risk assessment of the entity itself. A simple certificate might not be enough for a high-risk jurisdiction.
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