Financial Action Task Force

Identifying SBO in Pooled Investment Vehicles: Conundrum Continues

Summary: Identifying SBOs, especially if the member of a reporting company in India is a pooled investment vehicle of an overseas jurisdiction, continues to be a big challenge. The Indian SBO Rules provide for two different sets of tests for identifying an SBO, basis the PIV’s location. If a PIV is from a FATF compliant jurisdiction, the test is much simpler, vis-a- vis PIVs from non-compliant jurisdictions, which require more detailed scrutiny. This blog analyses several interpretative challenges that continue to bother both PIVs and reporting companies, requiring MCA clarification.Continue Reading Identifying SBO in Pooled Investment Vehicles: Conundrum Continues