Generally, the first step of identifying the beneficial owner (BO) referred to in "…situations in which ownership or control is exercised through a chain of ownership..." is by identifying the shareholders and directors, not the individuals appointed as executives e.g. CEO, CFO, COO, unless these executives are also the shareholders or directors.

The "chain" here is in relation to parent-subsidiary situations which extend across several levels, where the reporting institutions will need to review the entire chain of companies and subsidiaries to determine who is the ultimate beneficial owner of a particular customer that the reporting institution is dealing with.

However, reporting institutions should be aware that for BO of a legal person, if the natural person cannot be identified through the controlling ownership interest, then the senior management of that legal person e.g. CEO, CFO, COO or similar position is to be identified as the BO.

Details on the above sequential process to identify the BO can be found in paragraph 14.10.6 of the Policy Document.

For further details on beneficial owner, please refer to the “Guidance on Beneficial Ownership” issued by the Bank Negara Malaysia.

Please also refer to Part D of the Policy Document (Appendix 12).