Gap analysis vs FATF Rec. 10
ActiveI've reviewed Client M's policy against both FATF Rec. 10 §B and JYG Standard §3.2. Three material gaps on beneficial ownership:
Client M's Section 4.2.1 requires identification of the direct shareholder only. FATF Rec. 10 requires a cascade through all layers until a natural person with ≥25% control is identified. Internal standard §3.2(c) mirrors this.
Where no natural person meets the 25% threshold, FATF requires falling back to senior managing official. Client M's policy stops at "no identifiable BO" — leaves the file without an identified person. Reference: FATF Rec. 10 §5(b)(iii).
Identification step is present, but the policy doesn't require source-of-funds verification for politically exposed beneficial owners. Inconsistent with JYG Standard §3.2(g).
Want me to draft a revised Section 4.2 that addresses all three gaps, in Client M's existing voice? I'll match the phrasing patterns I observed in their other sections.
