Beneficial owner identification standards tightened for foreign portfolio investors, with thresholds, KYC reviews and compliance timelines. Beneficial Owners of FPIs must be identified per PMLA Rules: for companies/trusts on ownership (25%) and control bases, for partnerships/unincorporated associations on ownership (15%), with an optional 10% threshold for FPIs from high risk jurisdictions. Apply materiality at the FPI level and then look through material owners; if none, senior managing official is BO. BOs must not be nominees, on UN sanctions lists, or from FATF-deficient jurisdictions. Category II/III FPIs must certify and submit a specified BO list within six months; NRIs/OCIs and resident Indians cannot be BOs. FPIs must not issue or hold bearer shares and must complete periodic risk-based KYC reviews (annual for high risk, triennial for others).
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Beneficial owner identification standards tightened for foreign portfolio investors, with thresholds, KYC reviews and compliance timelines.
Beneficial Owners of FPIs must be identified per PMLA Rules: for companies/trusts on ownership (25%) and control bases, for partnerships/unincorporated associations on ownership (15%), with an optional 10% threshold for FPIs from high risk jurisdictions. Apply materiality at the FPI level and then look through material owners; if none, senior managing official is BO. BOs must not be nominees, on UN sanctions lists, or from FATF-deficient jurisdictions. Category II/III FPIs must certify and submit a specified BO list within six months; NRIs/OCIs and resident Indians cannot be BOs. FPIs must not issue or hold bearer shares and must complete periodic risk-based KYC reviews (annual for high risk, triennial for others).
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