Beneficial owner and person in a politically exposed position

The act on money laundering and financing of terrorism, obligates us as a credit institution to always clear our customers' ownership structures and control and i.e. the beneficial owners of the company. In addition, we are obligated to investigate whether the beneficiary owners are persons in a politically exposed position. We therefore recommend that you have information about ownership structure and beneficial owner available to complete the application.

Who is the company’s beneficial owner?

The company's beneficial owners are natural persons who own or hold more than 25 percent of the company's shares or voting rights - either directly or indirectly through one or several legal entities (such as companies or foundations) - or control the company in any other way.

If there is no such person, however, the legal entity must still appoint a beneficial owner. This person may be, for example, the Chairman of the Board, the Managing Director, an authorized company signatory or such. The company may also appoint several different beneficial owners.

Who is considered a person in a politically exposed position?
A politically exposed person means a physical person who has, or has in the past 18 months had, an important public function in a state or in an international organisation. You may also be a family member or closely related to a person in a politically exposed position.

Person in a politically exposed position can be:

  • Heads of State
  • The Prime Minister and other Ministers in the Government Offices
  • MPs
  • Judge of the Supreme Court and Supreme Administrative Court
  • The National Auditors
  • The Executive Board of the National Bank
  • Board members of Central Banks
  • Ambassadors or chargés d'affaires
  • Diplomatic Envoy
  • High Officers (General, General Lieutenant, General, Amiral, Vice-Master and Flag officer)
  • Board members and their deputies, as well as the CEO and his substitute in state-owned companies.
  • Person in charge of an international organisation (Board members, Secretary-General and such, for example UN, EU, NATO),
  • Members of the Board of Directors of a political party elected in the Parliament or the European Parliament.
  • Members of government agencies

In this context, individuals with the following connection to person in a politically exposed position are considered family:

  • spouse or registered partner
  • children
  • children’s spouse /registered partner
  • parent

Closely related is:

  • Known employee of a person in a politically exposed position. For example, a person who together with a person in a politically exposed position owns a company or otherwise controls the business of a company operated by a person in a politically exposed position or his/her family member.
  • Individuals who own or have influence over a company or other legal entity that has originally been formed in favour of a person in a politically exposed position or his/her family member.

What should I do if the ownership structure changes?
By signing the form the corporate customer undertakes to inform Eurocard of any essential changes in the ownership structure without undue delay in case such changes have an effect on the information that the company has previously provided Eurocard with. Therefore, in case the company has new beneficial owner(s) or any previous beneficial owner is no longer a beneficial owner due to changes in the ownership structure; or in case changes altering parent company's beneficial owners occur, must the company's authorized representative(s) return a signed form with updated information.