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KYC for company ownership: not all data comes from news

Chris Hamblin, Editor, London, 11 May 2016

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Many 'know your customer' software vendors use adverse media reports to provide their compliance customers with information; here Compliance Matters speaks to one firm that uses gazettes and directories instead.

DueDil, a 'know your customer' software vendor, is now offering a new feature that brings together corporate governance data for the purposes of revealing beneficial ownership. Its new 'tab' (a kind of 'dashboard' for compliance officers) gives the reader an all-in-one look at the ownership of a corporation, whether owned directly by a high-net-worth individual or perhaps indirectly through another body corporate.

Taking the example of Barclays Bank, if one looks at one page of the 'tab' entitled 'portfolio companies,' there is a drop-down menu of the 97 other companies that Barclays owns in the UK and/or Ireland. It shows percentage of ownership (Barclays Africa and Barclays Long Island are 100%-owned, Mccarthy & Stone plc a mere 7.36%) of each company, Barclays' share of net assets in pounds Sterling, and the company's status (dissolved or active or inactive) all in one chart. Another page looks at the related companies, proclaiming "Barclays may be related to the following UK and Irish companies for a number of reasons relating to governance and location. The table here intentionally excludes companies that are trivially [i.e. easily] identified as shareholders, group [companies] or portfolio companies." It has columns that display the similarity of each one's name with the name of Barclays as expressed by a percentage (Ebbgate Holdings Ltd is 29%, Barclays Capital Holdings Ltd is 52%, Clydesdale Bank is 67%), the number of major co-owners, the number of shared addresses, the number of co-investments, and status (i.e. active, inactive or dissolved).

The most noticeable feature here is the first column, headed 'confidence'. This shows how likely it is that the companies in question are related, according to the software. It is not expressed as a percentage (indeed, the percentage is never disclosed) but as 'high,' 'medium,' 'low' or 'unlikely.'

The 'tab' also contains a page that gives the names of shareholders, with information about the share types alongside. Barclays plc, then, has 2,342,559,513 shares of all types, making up 90.81% of the company's ownership, with the same number of shares being expressed again in the 'ordinary shares' column and therefore nothing in the 'preference shares' column. Bny (Nominees) Ltd, by contrast, have 237,058,133 shares of all kinds that make up 9.19% of the company's ownership, with nothing in the 'ordinary shares' column but 237,058,133 in the 'preference shares' column.

Another page shows directorships, bearing a list of them with their functions and ages (expressed down to the month, but with no actual dates of birth). There is also a handy summary of everything about the company, which in this example says that it has 83 directorships, 6 shareholders who use three share types, 97 portfolio companies (of which 31 are subsidiaries and 66 are 'minorities positions') and 117 related companies (12 bearing 'high confidence' and 29 'medium').

DueDil's spokesman told Compliance Matters that the 'confidence' rating that attempted to show whether two entities were related or not took information such as the number of major co-owners, shared addresses, co-directors, co-investments, name similarity and status and ran them through an algorithm that came up with a percentage. When asked where DueDil's information came from, he said: "All information is from the public domain. We take it from Companies House, gazettes such as the London & Edinburgh Gazette and the websites of the companies themselves. We geo-locate a lot of telephone numbers to work out where the addresses of various things are. You can then see the geographical spread of company offices and work out, for example, whether the company's big in Scotland, which is good for lead generation and sales but not so applicable to compliance officers.

"There is another feature, if you go to the summary page. Click on 'group' and you'll get a graphic showing all the related entities - it looks like planets and moons. It would be easier if it were a family tree."

The graphic shows large entities in each other's orbit, with their own smaller named satellites.

When asked whether the software covered countries outside the British Isles, the spokesman replied: "We provide information on 18 other countries in Europe, not to the same sophistication as the UK and Ireland. We don't in any way go to the same level of detail as the UK but - one day!"

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