True beneficial owner

According to the law (2017:630) on measures against money laundering and the financing of terrorism, a compliance officer is required to investigate whether the company has a true beneficial owner or if an alternative beneficial owner should be appointed. A compliance officer should assess whether the client or the client’s true beneficial owner is a person in a politically exposed position or a family member or known associate of such a person. Certain companies do not have to disclose the true beneficial owner to the Company Registration Office, but are still required to inform Ziklo Bank in accordance with anti-money laundering laws.

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Who is the true beneficial owner?

The true beneficial owner is the individual or individuals who, alone or together with associates, control more than 25% of the shares or votes in the company or otherwise exercise ultimate control over the company. For corporate clients without a legitimate beneficial owner, an officer must be appointed (the CEO, Chairman of the Board, or equivalent). Ziklo Bank is obligated to verify the information provided against the Companies Registration Office’s register of true beneficial owners, so it is essential to ensure that your information with the Companies Registration Office is up-to-date to avoid delays in handling your case.

When we compile information about the real owner, all personal data is handled in accordance with our data protection policy.

Companies exempt from providing information on beneficial owner

Companies listed on a regulated market (publicly traded companies) or subsidiaries of such companies are not required to disclose the true beneficial owner to Ziklo Bank. 

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Alternative beneficial owner – for companies without a beneficial owner

If there is no true beneficial owner, the Chairman of the Board, CEO, signatory, member of the executive management, or equivalent is considered to be the beneficial owner – also known as an alternative beneficial owner. According to anti-money laundering laws, Ziklo Bank must always know who the true owner is (exceptions mentioned in the above paragraph). 
Individuals who either directly or indirectly own or control the company must provide information about the legitimate beneficial owner. If the beneficial owner does not have a Swedish personal identification number, please provide the date of birth in full: YYYY-MM-DD.

What is PEP and RCA?

PEP (Politically Exposed Person)

PEP is an individual who currently holds or previously held a prominent public position in a state or international organisation, or is a relative (RCA) or associate of said person. Specify the position and the country where the individual served as a PEP. A prominent public position includes:  

  1. Heads of state or government, ministers, and vice or deputy ministers.
  2. Members of parliament and similarly legislative bodies.
  3. Members of the board of political parties.
  4. Judges of the Supreme Court, constitutional court, or other high-level justices whose decisions can only be appealed in exceptional cases.
  5. Senior officials of auditing authorities and governors of central banks.
  6. Ambassadors, heads of diplomatic missions, and high-ranking officers in the armed forces.
  7. Individuals serving on the administrative, management, or supervisory bodies of state-owned companies.
  8. Directors, deputy directors, board members of international organisations (as well individuals in similar positions).

RCA (Relatives and Close Associates)

RCA refers to spouse, registered partner, cohabitant, children and their spouse, registered partner, cohabitant, children and their spouse, registered partner, or cohabitant, and parents. Specify the degree of control (in percentages) and how it is exercised. If the true beneficial owner exercises indirect ownership/control through another company, that company must be identified. In the event of more complex ownership structures, an organisational matrix (or similar) illustrating the company's control structure should be attached when responding to KYC or due diligence inquiries.