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Thank You pyaari morning ladies and.gentlemen I'm hoping that you're feeling.bright and energized and not suffering.too much from the effects of your guided.tour and the great dinner that we had.last night because generally when you.say money laundering to people their.heart sinks and it's not necessarily the.topic that you would choose to have it.half-past 9:00 on a Friday morning and.even more so I think if you're a company.lawyer because if you're a company.lawyer like me you probably think money.laundering and think oh that's one of my.other colleagues who knows about that.and does something about that and I'm.here this morning to persuade you that.actually at least for this particular.aspect that I'm going to talk about.that's not the case and you are very.much the people who have to be involved.in this and understand what's going on.what I'm going to talk about this.morning it's not all of the directive.you'll be pleased to hear but I need.those bits of the directive which is a.2015 directive and you've got copies in.your background materials which relate.to who's a beneficial owner of a company.what does the directive say that they.have to do and also although the.directive is not yet implemented there.are already proposed changes to the.directive and then I thought what I.would do is share with you some of the.experience that we've had in the UK in.our efforts to start implementation of.the directive because I think although.I'm not suggesting that you necessarily.have to follow the solutions that we've.adopted in the UK it might be helpful.for you to know what sort of problems we.have encountered when we've been.thinking about this so as you know the.reason that we have directives on money.laundering and is because there has been.an increase in terrorist financing and.money laundering throughout the world.and the idea was that we should have.common measures and approaches as to.what countries and firms do to try and.stop that being the case the date for.implementation is June of next year.but the Commission has said that it's.very keen to encourage member states to.implement the directive early and they.would like member states to have done.that by the end of this year just a.couple of weeks ago I got in touch with.the Commission and asked which member.states had already implemented the.directive and they told me that at that.stage no member state had actually.informed them that they had implemented.the directive which is not to say that.member states are not necessarily.working hard to get to a situation where.they can implement the directive as.you'll see when I talk about what the UK.has been doing but I think it's.symptomatic of both the focus that the.Commission is putting on this and its.general importance that there is such a.push to get this directive into force.and people actually doing something the.other thing that it's worth remembering.is that this is a minimum harmonizing.directive so if any member state wants.to go further than the minimum standards.set by the directive they are free to do.so and so if you are in an organization.where you have to cope not only with the.requirements in your own member state.but setting up systems for your group.because your group operates in more than.one member state you will need to be.sure what approach each individual.member state is taking so that you come.up with standards that meet all of the.requirements not just the the minimum.set by the director so what the.directive is intended to do I thought.I'd give you just a brief overview on.this before we then concentrate on the.bits fur for companies is that it sets.out what a definition of money.laundering and terrorist financing is.and says that member states have to.prohibit that happening.and also member states have to make.assessments and individual firms have to.do risk assessments the people who are.affected by this directive are people.like financial services institutions.auditors tax advisers notaries and other.legal professionals trusts and companies.service providers estate agents and also.people who provide gambling services and.as we would typically think of money.laundering requirements it's mainly to.do with applying due diligence measures.to people who you are your customers in.order to try and identify who they are.and where the money that they're using.is coming from so for example I I with.my brother and sister at the moment and.buying a small piece of land in.Northampton in the middle of England and.I'm having to explain to my solicitor.where the small amount of money for this.piece of land is coming from as part of.these due diligence measures at a much.higher level member states have to make.sure that they have a financial.intelligence unit and firms are required.to report to this financial intelligence.unit on their own initiative if they.know or suspect or have reasonable.grounds to suspect that funds are the.proceeds of a criminal activity or are.related to terrorist financing the.directive has provisions about data.protection how you keep records what.statistical data you have to collect and.provide and firms that are part of a.group have to have Greek wide policies.and procedures and that they implement.in order to deal with with these aspects.and the national competent authorities.have to monitor whether these policies.are working effectively and that people.are taking measures to make sure that.there is compliance but the bit that.whips tickly interested in this morning.is the bit that deals with beneficial.ownership information particularly in.relation.to companies so the 100 million dollar.question maybe even more than that is.who is a beneficial owner and anyone who.has followed the discussions in the.corporate governance area about who are.the ultimate owners or beneficial owners.whatever phrase you use to describe this.person is a really vexed question and.hard to do but this directive gives us a.definition so what article 2 says is.that a beneficial owner is any natural.person so it has to be a real person not.a not a company who ultimately owns or.controls a customer or it could be a.real person on whose behalf a.transaction or an activity is being.conducted and then the bit that we're.interested in in the case of corporate.entities it tells you that at least.certain people must be treated as being.the beneficial owners of the company so.the question you have to ask yourself.for a company is who are the natural.person or persons who ultimately own or.control that company and they can do.that in a number of ways they can either.do it through direct ownership or.indirect ownership and it has to be.ownership of a sufficient percentage.either of the shares of the company or.the voting rights in the company or some.other ownership interest in that company.and I think that last category is there.to try and accommodate the the many.different corporate forms that we find.in the different member states the.definition makes it clear that bearer.shares count for this purpose and it.also makes it clear that if you can.control the company in some other way.that is also caught so you can see it's.a very wide definition there are.to cases where companies are not covered.by the directive and that's because they.are subject to existing requirements so.if you're a company who is listed on a.regulated market which is subject to.disclosure requirements which are.consistent with EU law so if you're a.blister company in you're subject to the.transparency directive requirements then.you're not subject to these requirements.and similarly if you're a company which.is subject to equivalent international.standards which make sure that there's.adequate transparency of ownership.information then you're exempt as well.and the reason for that is you'll.remember under the transparency.directive there are already requirements.for people who have an interest in the.voting shares of their listed company to.notify and that gets notified to the.company and through the company to the.market as a whole so the market knows.who are the people who have control over.that entity and so because there were.those provisions already and that.information is already in the public.domain.it wasn't felt necessary to include.those companies within these.requirements the directive also tells.you what what should be taken as an.indication of direct ownership so if.you've got a shareholding of 25 percent.plus one share or you've got an.ownership interest of more than 25.percent which is held by a natural.person then that will that must be.caught in the definition and I find.diagrams helpful when I'm thinking about.these things so if you imagine that the.company that you're you're worrying.about is the one at the bottom and you.know that there are three individuals.who are shareholders in that company one.of whom has 30 percent another 50.percent and a third one 20 percent under.that definition of direct ownership.individuals one and two would be caught.as beneficial owners but individual.three wouldn't assuming that there.and their other relevant facts that.apply to individual three because.they've got less than 25 percent the.directive also tells you about indirect.ownership and what's to be treated as an.indication of indirect ownership and.here it's where you've got a.shareholding of 25 percent plus one.share or an ownership interest of more.than 25 percent which is held by a.corporate entity and that corporate.entity is under the control of an actual.person or there are multiple corporate.entities which are under the control of.the same natural person or persons so.again if I give you that in the form of.a diagram so you've got an individual at.the top who controls two companies and.then each of those companies has a share.of more than 25 percent then the.individual will be treated as being a.beneficial owner for the purpose of the.directive now the directive is very.flexible and what it says is that member.states can decide if they want to that.something lower than 25 percent is to be.treated as an indication of ownership or.control so if if your particular member.state feels that 20 percent is enough to.give you control they are they can make.that decision also another option that.the directive gives you is to say you.can apply the tests that are relevant.for when a parent undertaking has to.prepare consolidated accounts and use.those as a way of deciding when somebody.has got control and I'll come to those.in a second interestingly and I think.this is a bit of bad drafting in the in.the directive the definition goes on.actually to impose a substantive.obligation because the definition says.if the company when it looks at the.information that it's got and decides.that it can't identify anyone or if it's.in any doubt.then what it must do is it must record.what action it's taken to identify its.beneficial owners now obviously the the.test for when a company has to prepare.consolidated accounts is quite a useful.test for companies because they are.already under obligations and the.directive to produce consolidated.accounts in certain cases and it's quite.helpful I think to be able to use this.as one of the ways of determining which.holders are controlled so if you have a.company which owns most of the.shareholders or members voting rights in.another company you'd have to prepare.consolidated accounts or if you can.appoint or remove most of the members of.the administrative management or.Supervisory Board of a company and.you're a shareholder or member of that.subsidiary undertaking you prepare.consolidated accounts or if you can.exercise dominant influence and it.doesn't matter whether you're doing that.under a contract or through a provision.in your constitutional documents and.you're a shareholder or member of that.company that's another situation where.you prepare consolidated accounts or the.last one is where in fact most of the.members of the administrative management.or supervisory bodies have been.appointed as a result of you exercising.the weight so that could be that the.other shareholders haven't bothered or.never bother to vote on things say that.even though you might not technically.have enough votes to control in practice.you do say or you might have an.agreement with one of the other.shareholders or members so that they.always vote with you and through that.agreement you can control a majority of.the voting rights in the in the other.company and that's another case where.you would prepare consolidated accounts.the definition of beneficial owners for.the purpose of the directive goes beyond.what's relevant for companies but I.thought it was still worth mentioning.this because very often as company.lawyers we do deal with trusts and.similar entities what it says for trusts.is that the beneficial owners are the.set law the trustees a protector if you.have a protector the beneficiaries of.the trust or if you can't yet work out.who the beneficiaries are going to be.the people for whom the arrangement has.mainly been set up or operates and then.any other natural person that exercises.control over the trust whether that's.direct or indirect ownership or in some.other way and similarly for foundations.or any other legal arrangements that are.similar to trusts it's any real person.any natural person who holds an.equivalent or similar position to the.ones that I've just described for trusts.so again you can see a very broad range.of people who are caught in the.beneficial owner definition so what is.it that you have to do well the people.who have to take action are the.companies themselves or the other legal.entities and for every member state its.the companies that are incorporated.within that particular member state what.the directive says is that you have to.obtain and keep adequate accurate and.current information on the people who.are their beneficial owners and the.details of the interests that they hold.and also that if somebody who's an.obliged entity so a notary or a gambling.company or whoever it is he's trying to.do customer due diligence if they come.to you and need that information as part.of their customer due diligence measures.then you have to provide the information.that you have about your benefits.to those obliged entities and the.directive also says that the information.has to be kept in a central register in.the Member State there's a bit of.flexibility as to how the Member State.does that so it could be in a commercial.register or the company's register or.some other sort of public register and.the Member State has to tell the.Commission what the characteristics of.the mechanism that they've chosen are.and they're allowed to collect the.information that they need on beneficial.ownership in accordance with their own.national system so there's some degree.of flexibility for every member state as.to exactly how that collection of.information and recording works once the.company's got the information who are.the people who can have access to it.well firstly and importantly the.competent authorities and the financial.intelligence units and they must be able.to have access to the information in a.timely manner and without any.restrictions the other people are.obliged entities as long as they are.following the requirements for customer.due diligence under the directive but.also anyone else any other person or.organisation as long as they can show.that they've got a legitimate interest.and the directive sets out what.information they are allowed to have.access to and that must be at least the.name month and year of birth of the.beneficial owner their nationality where.they reside and what the nature and.extent of the beneficial interest is.data protection rules apply to all of.this and as anyone knows data protection.seems to become a more vexed topic on on.a daily basis trying to get the balance.between the rights of the individual to.be protected and the rights of.authorities and others you have a.legitimate interest in that information.one of the things that member states can.do is that they can say.that somebody who wants access to the.information has to register online and.you are allowed to charge a fee for it.but the fee is not allowed to exceed the.administrative costs of providing the.information the system has to work in a.way so that when a competent authority.or a financial intelligence unit wants.access to the information that they can.get access without the relevant person.knowing that that's the case and it's.not just the competent authorities and.financial intelligence units from your.own Member State who are allowed access.to this information the system has to.work in a way that if a competent.authority from another member state or a.financial intelligence unit from another.member state wants access to this.information you have to be able to.provide them with access to the.information in a timely manner as well.the directive does set out some.exemptions but member states have an.option to apply if they want to do so.they don't have to include these.exemptions in their national legislation.but the exemptions can't apply when it's.either a competent authority or a.financial intelligence unit who wants.access to the information but in other.cases Member States can say that you.don't have to provide access to.information on a case-by-case basis and.exceptional circumstances and that's.where access to the information will.expose the beneficial owner to a risk of.fraud or kidnapping blackmail violence.or intimidation or where the beneficial.owner is a minor or is otherwise.incapable in some way and then the the.last thing to mention from the directive.is the fact that the directive says that.by June 2019 the Commission must put.forward a report to the Parliament as to.how there could be a proper.interconnection between the various.registries in the member states that.hold the bits of information and.yesterday we were talking about.interconnection project and the.directive foresaw that it would be.really helpful if the information being.kept in the various registries could be.interconnected in that way and what the.directive says is that where it's.thought appropriate the report should be.accompanied by a legislative proposal.but the directive has already been.superseded by events because as I said.before we even got to the date by which.the directive has to be implemented we.already have proposed changes to the.directive I think as P was saying.earlier this morning we are seeing at.the moment a fall in the trust that the.general public has in companies and the.people behind companies and events like.the Panama papers do nothing to reassure.the general public that on the whole the.majority of companies are legitimate.businesses carrying on business for the.benefit not just of the people who set.them up but for the people who work for.them and for society generally but there.is there's a I think greater degree of.concern about companies and who owns.them and I think this is driving some of.the the proposals about making sure that.there is more transparency of.information about who owns companies and.what they do and so one of the proposals.is that one of the company law.directives directive 2009 101 which is.the directive that replaced the first.company law directive and sets out what.information has to be kept in relation.to companies and a central register in a.member state the proposed change is that.that directive should be amended so that.the information on beneficial owners.will be disclosed under that directive.and it's also being proposed that you.would no longer need to demonstrate a.legitimate interest in order to have.access to the information about who are.the beneficial owners.and reflecting some of the data.protection concerns it's also proposed.that information shouldn't be available.for more than ten years after a.company's been struck off and that the.interconnection of the registers should.be brought forward so rather than there.just being a report and the proposal.this directive all this proposed.directive is is suggesting now that that.should happen the other thing is that.it's proposed that for certain sorts of.entities what counts as an indication of.ownership or control should be reduced.down from 25 percent to 10 percent and.this applies to what are called passive.non-financial entities and they're.defined in directive 2011 16 and these.are basically entities that are there.just to be an intermediary they don't.create income of their own and they are.there mostly to channel income from.other sources and I think because there.is particular concern about what are.entities like that they're to do it's.felt appropriate that the test that you.apply to those entities should be lower.than the normal test for what would.constitute control it's also being.proposed that certain sorts of competent.authorities should definitely fall.within the competence of authorities you.have access to this information so if.you're an authority with responsibility.for money laundering or terrorists.finance something like a tax authority.or an authority which prosecutes money.laundering or is responsible for tracing.and confiscating from assets that you.you should definitely be one of the.types of authorities that would always.have access to the information and also.if you have any sort of credit.institutions or financial institutions.or obliged entities that are some sort.of public official that the exemptions.as that would stop you getting access to.the information and shouldn't apply and.as I say that the central register.should be connected.this proposal is a me been put forward.this summer so where it's still in the.early stages of how the discussion is.going to go on that but we should keep.an eye on that so I promised I would.talk a little bit about our UK.experience as pyaari said David Cameron.what has been a great proponent of the.UK being at the forefront of taking.action in this area and so we have been.discussing this for quite some time and.I have to tell you that our experience.as UK lawyers is it's really tricky if I.had counted up all of the hours that I.have spent trying to understand what the.government was trying to do and the.discussions that we have in in London we.have a group of company law lawyers.under the auspices of the City of London.Law Society so a representative from all.the big city firms who practice in this.area it would be thousands and thousands.of hours and that's just when we discuss.it amongst ourselves we have written.very long papers for government about.what their proposals are and how it's.going to work in practice and when you.put yourself into the position of the.person in the company here is the person.responsible for collecting this.information keeping it keeping it up to.date and thinking about what happens.when things don't quite work as planned.you begin to realize how much time it's.going to take up for those lots of.people what we did was we made changes.to our Companies Act it came through.something called the small business.enterprise in Employment Act 2015 which.received Royal Assent in 2015 and came.into force in April of this year so.we've got primary legislation but we.also have to lots of secondary.legislation so the more detailed stuff.which are very long and because we.thought no one would make head or tail.of the words in the legislation itself.we have three lots of guidance for.people who are trying to deal with this.area so firstly we have.some statutory guidance so that's.guidance that the courts must look at.when they are trying to work out what.the meaning of significant influence or.control is and that guidance is 14 pages.long lots of people said well lots of.Company Secretaries won't have a time to.read that so we need something shorter.so we produced a summary guide for.companies because we were trying to help.small companies which have relatively.simple Affairs get to grips with what.they needed to do without complicating.it for them if they didn't need to so.the summary guidance is five pages long.but the guidance you really need to read.particularly if you're advising on this.is the last guidance which is for people.who have significant role and that is 47.pages long and it's the sort of thing.where you get your cold towel out in.advance and you settle down and you make.sure that no one is going to distract.you while you read it so you know you're.feeling that you can't go to sleep and.you're in need of something all this.guidance is available online and it will.only take you half a page and you'll be.feeling very drowsy indeed so what were.the sort of things that we were trying.to get to grips with us we were trying.to implement this who do we count as a.person with significant control that's.the a person with significant control or.a PSC is the jargon that the UK has.chosen to use to be the equivalent of.who is a beneficial owner and I think.that's partly because in in the English.legal system beneficial owner already.has a particular meaning and we didn't.want to confuse that meaning with what.we were required to do for directive.purposes and interestingly what the.government has decided is that if you're.a government or a local authority or an.international organization for the.purposes of our legislation we're going.to treat you as though you were an.individual which wouldn't be necessarily.obvious next question what if you've got.joint holders of a share well what we.decided was that each of the joint.holders will be treated.as holding the shares or the rights that.they have so that you treat them.separately and you treat both of them as.being beneficial owners what if you have.a situation where you've got somebody.who's acting as a nominee for somebody.else we decided that we would look.through the nominees so we wouldn't.treat the nominee.as being a beneficial owner we would.treat the person for whom they were.holding the shares as being the.beneficial owner.what if somebody owns the shares but.it's used the shares by way of security.for some loan or something else we.decided that we would continue to treat.the person who had given the security.over the shares as being the beneficial.owner of the shares rather than the.person to whom they had transferred the.shares or given the shares by way of.security what do you do when there are.rights attaching to shares which are.only exercisable in certain.circumstances and it may vary from.member state to member state but in the.UK we're very flexible about the rights.that you can attach to shares and if you.can think something and write it down.then you can make that a write that.attaches to a share so it's quite usual.in the UK to say that a share will only.have voting rights in particular.circumstances and what we decided on.that was that you would treat the right.as being exercisable only whilst the.relevant circumstances apply or if the.person can control whether the.circumstances apply or not say they are.in affecting control we would treat them.as as if the rights were applying even.though they hadn't actually exercised.their control yet to make the rights.apply and what other cases should fall.within situations where somebody.exercises significant influence or.control in practice and what about when.they're doing that through a trust or a.firm those are the sorts of bits where.we get into such a degree of detail that.I didn't really think it's helpful to.you for me to spend a lot of time.explaining the conclusion.that we came to but if you're interested.there in the guidance what other things.did we think about where does the.company keep its register in the UK.traditionally companies have been.required to keep all of their company.records at their registered office but.there has been a bit of a trend in the.last 5 years or so to start making.better use of digital technology and.allowing companies if they want to do so.to keep some of the information they're.required to keep under our Companies Act.with the central registry so we have an.option at the moment for the UK so that.companies can choose rather than keeping.a register their registered office to.keep it at Companies House exactly what.information do they have to put into.their register if you're the company's.secretary or the person who's got this.job you need to know what information it.is you've got to put into the register.how often do you have to update the.information in your register remember.that the directive says that you have to.keep accurate information so as the.person at the company who's you've just.prepared your register when do you next.have to go back to the people who you.think are the beneficial owners and.check that that's still the case and.that they haven't for example decided to.give their shares or the beneficial.ownership of their shares to a child or.a husband or wife or some other third.party or entered into some new.arrangement you know so how often do you.have to check on that or you know in.what circumstances when should you be.put on notice and I think that's quite a.difficult thing because it's obviously.you know you can't be doing it on a.daily basis the world will come to a.stop if you do nothing except ask for.information about beneficial ownership.of shares where we got to in the UK was.when you become aware of a change you.should take some.what do you do if you write to the.person who you think is the beneficial.owner and they don't reply to you and I.think the answer to that is you go back.to what I was talking about you know you.record the steps that you've taken and.if you can't get an answer out of.something you can't get an answer out of.them what if you maybe don't know who.the beneficial owner is but you've been.dealing with an adviser that they have.that's a legal adviser or some other.third party it's your Member State going.to put an obligation on those people to.provide information to you how does that.fit with things like legal professional.privilege what do you do as the company.if you write to them and they don't.provide information to you one of the.things we decided in the UK and this.came after quite a lot of discussion.with the government was that in addition.to putting an obligation on the company.to ask for information we felt that.there should also be an obligation on.the people who are the beneficial owners.themselves to provide information to the.company now the directive doesn't.require you to do that but we felt that.to have a workable system that was an.appropriate thing to do.what penalties and sanctions are you.going to apply if somebody doesn't.provide information when they are.supposed to do that and how are those.going to work we had had in the past in.the UK provisions which required people.who were interested in shares to provide.information to the company and it's.quite usual for companies in the UK.particularly listed companies to have.provisions in their articles that say if.people don't provide information to the.company when they are required to do so.that you can suspend the rights.attaching to their shares so you.wouldn't have to pay them dividends they.wouldn't be able to vote at shareholder.meetings until they provide the.information because we think that's the.way that you really get people's.attention is by saying you can't.your money you can't exercise your.influence whilst you're not complying.with the requirements but is that the.right approach to take and how do you.protect people who may be involved in a.chain of ownership if you if you apply a.sanction like stopping dividends or.preventing people from exercising voting.rights there may be innocent third.parties as part of that ownership chain.who are going to suffer in some way.because you've applied the sanction and.do you need a process under which they.can somehow intervene as between the.company and the person who hasn't.provided the information in order to.protect their own position and what if.the company makes a mistake and shows.you as being a beneficial owner of the.shares in circumstances where you don't.think that that is the right approach so.we decided we ought to have a process.for rectifying an incorrect register and.so you can see that all of that is is.quite complicated and there's quite a.lot of things to think about the other.thing that the directive doesn't really.go into any detail about is how does all.of this work in a group of companies.which is the company in the group of.companies that keeps the register and.what information must it keep and one of.the problems I think with the directive.is that it applies on an entity by.entity basis so the directives.presumption seems to be that every.company has to keep its own register.which means that throughout a group.you're going to be duplicating the same.amount of information a lot of times and.interestingly although there's an.exemption for listed companies there.isn't an equivalent exemption for.subsidiaries of listed companies so you.get the situation where the listed.company at the top doesn't have to have.a register of its own because it's.reporting information under the.transparency directive but the.subsidiaries of that listed company are.subject to this requirement.and how does this work whereas is.usually the case in complicated groups.of companies you've got companies which.aren't in your own member state.somewhere in the chain of ownership and.that might be in another member state.but it might be a country outside the EU.which may have no equivalent sorts of.requirements and I thought I'd finish.just by giving you a couple of examples.I should warn you that these please.don't take these as being the right.approach for the directive because in.certain cases the way that the UK has.chosen to implement the directive I.think goes further than the directive.actually requires and we have adopted a.particular approach so if I start off.with a simple example say you're.thinking about Company A at the bottom.of my screen and you're trying to work.out who should company a show in its.register of beneficial owners and assume.that company a is a subsidiary of.another UK company which owns more than.25% of its share capital and that that.company then has another UK company.which also ends more than 25% and.there's a majority of Company B the way.that we have made it work is that in.order not to duplicating information in.the various companies registers instead.of getting every company to put the same.information we just look up and you if.you've got a company above you which is.also subject to UK requirements for.keeping a register you just put the name.of that company in your register and.then that means that the person who.looks at your register would know that.they have to go and look at the register.of that company and so somebody looking.at accessing this information has to.work their way up the chain until they.find the company which has got the sort.of ultimate beneficial owner information.in it.what about if you have a similar sort of.makeup but the company at the bottom is.owned by a non UK company but the non UK.company is owned by an individual who.has a majority stake in this non UK.company in that case what the UK company.do would do would be to show the.individual as being the beneficial owner.on its register so it looks through the.other company and the reason that the UK.decided to do that was because being a.non UK company it's not subject to our.regime and we weren't there for sure.exactly what information it would be.showing so in that case we say the UK.company has to record the information.about the ultimate beneficial owner if.you have a case where you don't have any.beneficial owners so say you have a.company and it's got five individuals.and all of them hold less than 25% of.the shares and assume for the sake of.this example that they don't own or.control in any way so there are narrow.agreements between the shareholders or.anything like that what your register.would say is that the company either.knows or has reasonable cause to believe.that there isn't anybody who's.registered and so if you looked at the.register that's what it would tell you.and what about if the interests are held.indirectly so this is a case where the.company has an individual who has.majority stakes in two other companies.and those companies when you put them.together have more than a 25 percent.interest so in that case under the UK.approach and you'd look through the.legal entities and you'd put the name of.the individual onto your register now.those are pretty simple examples and you.will know from looking at group.structures that it's not difficult to.come up with examples which are much.more complicated than that and if you.think about private equity groups where.you start getting trusts involved or.people using limited liability.partnership structures and things like.that you can see how quickly it can.become quite complicated to work out.whether a particular person has a.controlling interest or not and whether.they should be shown as being a.beneficial owner or not I hope that.gives you some idea of the sorts of.things that we have thought about the UK.hasn't finished implementing the.directive in fact just a couple of weeks.ago a consultation paper came out from.the government looking at the ways in.which they might implement the remaining.parts of the directive relating to.trusts and things equivalent to trusts.and one of the things that we're going.to have to change is at the moment.companies only have to provide the.information on beneficial owners to the.central registry once a year where is.what the directive requires us to do is.to make that information available all.the time and the consultation paper is.asking about what's the best way to do.that obviously if you've opted to use.the central registry as the place where.you keep your record it will be being.kept up to date as you make your changes.to it but that's not the case for all.companies so good luck it it is I think.it's it's something that we're going to.have to get to grips with more because I.don't think the pressure for who are the.people behind companies is going to be.any less at any time in the near future.maybe we will get better at working out.how to work out who these people are.what are the tests that we apply.generally I find that the more we do.something the better we get at it I.certainly hope so and I'm happy to.answer any questions you might have as.always they're not too technical.questions.

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