Entity Screen
Beneficial Ownership
Quick answer. Beneficial ownership asks who owns or controls an entity, not who the registered agent is. Public secretary of state filings often do not answer it. Entity screening asks who the legal entity is, whether sanctions lists name it or its owners, and what credible public reporting says. Adverse media is not an OFAC list. Beneficial ownership is not the registered agent.
Official office
Office of Foreign Assets Control
Steps
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Identify the legal entity
State, file number, status, date viewed.
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Screen names on OFAC
Entity and people, separately, with the search date.
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Read adverse media as news
Cite the original report. Ignore duplicate reposts.
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Ask for ownership documents
Do not invent members from the registered agent.
Beneficial ownership is who ultimately owns or controls
Use the charter to get the legal name and status, then use ownership documents the company provides for the people. Do not invent members from the agent’s name.
Federal beneficial-ownership reporting rules have changed. Do not quote a filing deadline from memory. Read the current FinCEN instruction if a form asks about a government BOI filing. This site does not submit that form.
Separate the sources in the file
Pull the state file for the legal name, number, and status. Screen that name and the known owners in OFAC’s tool. Read adverse media as articles with dates, not as a second sanctions list. PEP screening looks for public roles under your policy.
Beneficial ownership comes from documents the company provides when the state file is silent. Federal BOI rules have changed. Read the current FinCEN page before you quote a filing duty. We do not submit that form.
Common mistakes
- Rating a company from headlines alone.
- Calling the agent the beneficial owner.
- Merging PEP and SDN labels.
- Quoting an outdated BOI deadline.
Questions
What is adverse media screening?
A review of credible reports about crime, fraud, or corruption. It is not an official sanctions list.
What is PEP screening?
A check for prominent public roles under your policy. It is not automatically a sanctions hit.
What is AML screening here?
The stack of sanctions, media or PEP checks you adopted, plus the legal-entity file. It is not a certificate of low risk.