Saturday, July 30, 2016


I am seeing discussions around whether to perform due diligence upon what the authors describe as the "Intermediate Beneficial Owner," and hasten to remind readers that any intermediary, post-transaction, is most likely a front man/woman whose purpose is to either hide the name of the Beneficial Owner, or perform some other illicit act, such as assist in tax evasion, money laundering, trade-based money laundering, or something else that is not-legitimate.

Please do not dignify such an individual as anything other than that which he or she really is, a manipulator. Remember,  frontmen or nominees routinely show up as owners of a corp at closing of the transaction, and then, immediately, quietly convey out to someone whom you would not otherwise deal with. There's no honor in being a intermediary, and it just confuses young compliance officers, to label someone an intermediary beneficial owner, when that is NOT what they are. Watch your terminology, please. Do not use Ultimate Beneficial Owner, for that connotes others in the mix, of equal dignity.

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