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Asked by

Community Member

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Fund Compliance

A potential LP is a US based C-Corp owned entirely by a Canadian Limited Partnership company. The Onboarding questionnaire has the following question: "Who owns this entity? Please confirm the full legal name, date of birth, and city and country of residence of any individual who owns 25% or more of the entity you are using to invest.". My question is the LP should just inform that the Canadian Limited Partnership is the "owner"?

My question is the LP should just inform that the Canadian Limited Partnership is the "owner"? Or goes upstream ? What to answer if no individual has more than 25% of the Canadian LP? 
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Answered by

Magdalena Mielczarek

on

For the Anti Money Laundering portion of the review we are always looking for the underlying individuals.

It means that if there are any entities that are owners with 25% or more interest in the LP entity, we will require the name(s) and date(s) of birth of the underlying individuals of that subsidiary entity/entities.

In the case where there are no underlying owners with 25% or more interest in the LP entity (directly or through its subsidiaries), it will be required to review the next person who has the authority and control to be the decision-maker in the LP entity. We will need the name(s) and date(s) of birth of that individual(s).

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