TABLE OF CONTENTS


First AML’s ‘unwrap’ feature combines our entity tree builder with up-to-date company registry data from various global registries. With just a simple click, users can effortlessly request company registry information for any private company. The entity tree will automatically populate with the Directors and Shareholders details in order to identify beneficial owners.


Please note there is a billable charge for each unwrap. The cost varies depending on the entity's jurisdiction. Please contact [email protected] for further information on costings.   


Video demonstration




Step-by-step


  1. Click ‘Create new case’
  2. Enter information in the below fields:
    -Primary entity type: select ‘Private company’
    -Verification type: select verification type for the beneficial owners (more information here: Verification types)
    -Find an entity*: enter the full legal name of the Private Company
    -Registered country*: select the country the Private Company is registered to
    -Company registry number: enter the Private Company’s registration number
    -Case reference (optional): option to enter an internal reference for the client
    *These fields are mandatory to enable KYB unwrap
  3. Click ‘Create case’



4. Click the ‘Structure’ tab

5. Click ‘Start unwrap’*

*Some countries can have multiple different companies sharing the same company registry number. In this case, we will present these companies to you so that you can confirm the correct company to unwrap.




6. Review the unwrap. The structure tab will populate with the Directors and Shareholders, retrieving information from the registry search. We recommend you review the company extract after unwrap. This can identify useful information specific to certain registries, and provide more context on shareholding percentages. 


6a. Where an entity is associated with the shareholding, you will need to confirm the entity to ensure accurate matching of the shareholding entity name from the register with the corresponding entity from our global registry search. Click ‘Confirm entity’


6b. Select the correct shareholding entity* and click ‘Confirm entity’ *A global registry search is automatically performed using the entity name, and you will see details of any entities that match the search criteria.

It is likely that there will be multiple entities returned. In most cases the correct entity will be clear, but in some cases you may need to request shareholding confirmation from your customer in order to identify the correct entity if you are unsure.

If you cannot find an appropriate entity, please be aware that:

  • Only active companies will appear in search results. The entity in question may not be active, or may not be listed in a company registry.
  • The search can be sensitive, and occasionally small differences can result in undesired matching. We recommend you try adjusting the search criteria to remove company type labels like "Ltd" or “Limited”.
  • It is possible that the entity name has been changed on the local registry, but this has not yet flowed through to the global search.




6c.  Once the shareholding entity is confirmed, the entity will be updated with the information from the registry, including: name, registered country, company registry number, address, and entity type.


If the entity is identified as a private company, it will be available for unwrap. If this is the case, repeat steps 5-6b.


If the entity type shows “Other”, it is not a private company, and we have not been able to map the entity type. You can view the company extract to identify the entity type, and change the entity type manually in the entity profile.




Extra tips


Reviewing the Company Extract 


After unwrapping an entity, to access the company extract downloaded from the registry:

  1. Click on an unwrapped entity from the entity structure tab
  2. Click on ‘Manifest’ tab
  3. The Company Extract is shown and can be viewed and downloaded.

The Company Extract can also be found directly from the Case > Requirements tab




Share class representation 

Sometimes you may see an individual with multiple Shareholder percentages within a single entity. This represents that the individual has multiple shareholdings. Sometimes this percentage can display 0%, indicating that the numbers of these shares are extremely low, and suggesting the possibility of controlling powers within this share class that requires further investigation.


You can view the company extract <link> to see the share counts for each shareholding.


Cancelling an unwrap

We understand that there may be times that you request an unwrap for a company which may be in a jurisdiction which has a timeframe associated with the data collection only to need to cancel it owing to various reasons. 


You are able to cancel the unwrap, however there will still be charges associated with the request. 





Max entity/individual limit is 50

For companies with very large numbers of individuals and entities (more than 50 individuals or 50 entities), the entity structure will not be automatically unwrapped.


This is due to the large numbers of very low percentage shareholders that will be created in the entity structure and the Manifest, resulting in additional work cleaning up potentially unnecessary records.


In this case, we recommend reviewing the company extract and manually editing the entity structure to better represent key shareholders.




Individual matching

We perform automatic exact name matching when individuals are identified multiple times across the structure. This ensures individuals are only represented for you once within the Manifest. However, any differences in name (i.e. a middle name present) and we will not automatically match the individual, leaving this to you to review.


If you need to manually match an existing individual, you can easily do this when adding an individual to the structure. Typing their name will show any “IN CASE” matches, making it easy to match the new individual and enter their ownership information. Once this is done, the unmatched individual can be deleted from the entity structure.


Non-beneficially held shareholding

For Australian entities, the company information retrieved from ASIC (Australian Securities and Investments Commission) will identify when a shareholding is non-beneficially held.

When this has been identified, we will highlight for you the entity that holds this non-beneficial shareholding.

This means the flagged entity is holding the share as a trustee, for the entity that receives the direct benefit of the shares, which is most likely a trust.

In this case, we represent the following in the entity structure:

  1.  A placeholder trust is created, holding the shareholding percentage identified for the non-beneficially held entity from ASIC.
  2. The non-beneficially held shareholding entity is represented as a controlling entity of the trust.

The reason this trust is not identified by the unwrap, is because trust information is not available from the ASIC registry.


The placeholder trust will be visible in the Manifest, and you can then request the required documents such as a certified trust deed and certified deed of amendment.

If you identify that the placeholder entity is not a trust, the entity type can be changed by selecting the trust when editing the entity structure.



Shareholding Entities with 'Trustee' in the company name

For New Zealand private companies which have the word 'Trustee' within the company name (i.e. ABC Trustee Limited) are often holding shares on behalf of a Trust and the recommendation would be for a trust deed to be collected as part of the verification to ensure all individuals with effective control are being identified. 


Joint Shareholding

For New Zealand entities where the company information is retrieved from the New Zealand companies office there will be situations where the shareholding entity will be unwrapped to be an entity titled Joint Shareholding. 


The way that the companies office in New Zealand is set up, is that if there is a Trust in shareholding that it will show on the company extract that the shares within the Trust are jointly held on behalf of the Trust. We cannot confirm whether or not that the retrieved Joint Shareholding is a Trust or in fact jointly held shares.


The recommendation would be to discuss with your client and if it is a Trust you can edit the type of entity and request the required documents such as Trust Deed, Deed of Amendments or whatever documents are appropriate within your compliance program.