Swedbank and the beneficial ownership rule

Author: Bobby Hussain | ICA inCOMPLIANCE® Magazine, Issue 61 (2022)

This article dissects Swedbank’s failure to identify beneficial ownership across complex corporate structures, drawing on the Clifford Chance report and English trust law. It highlights how nominee arrangements and inadequate documentation undermined AML compliance, particularly in relation to Dutch stichtingen. The piece offers a practical framework for verifying beneficial ownership—emphasising certified documentation, centralised storage, and clear separation of legal and equitable interests. It calls for stronger internal protocols and regulatory alignment to prevent future breaches.