In October 2025, updated demands for informing beneficial ownership came into force as part of fight against money laundering, terrorist financing and sanctions avoidance. Main changes affect practice of comparing notification about beneficial owners obtained from clients with branded corporate possession registers.
Current informing demands are designed to eliminate data gaps, improve accuracy of registers and strengthen control over openness of corporate structures. In this regard, our services provided by ELI Canada – customer-oriented financial, legal and consulting services provided by qualified specialists – enable organisations to adapt to new requirements and correctly build internal reporting processes.
This isn’t about directly expanding declarations on beneficial owners as such, but about introducing obligation to record and inform significant inconsistencies among financial intermediary’s internal information and official registry data. This change reflects shift in emphasis from simply collecting notification to verifying its quality and comparability with government sources, which makes use of professional support relevant.
Current demands apply to all informing objects accountable to Financial Transactions and Reports Analysis Centre of Canada, which are mandatory to accumulate and validate data on beneficial owners in course of their activities. These entities include financial intermediaries, banks, money transfer services, leasing firms, factoring organisations and other categories specified in current anti-money laundering legislation.
Obligation comes into effect when entity identifies corporation that is subject to demands and assesses it as merriam-webster in relation to likelihood of involvement in money laundering, terrorist financing or sanctions avoidance.
Substantial variance is significant inconsistency among notification about beneficial owners acquired from customer and notification about persons with substantial influence available in public registers. Such discrepancy refers to cases where list of owners differs significantly, key owners are omitted, or data significantly contradicts official record.
Minor errors in presentation, typographical errors or other technical inconsistencies that don`t affect actual composition of owners and control of company aren`t considered material. Determination of “materiality” remains matter of judgement in specific circumstances and requires internal decision by relevant specialist.
Informing item shall:
Report must contain reporting entity’s identification details, notification about corporate client, and precise description of nature of discrepancy. According to demands, items are obliged to retain confirmation of submission and documentary evidence in accordance with regulatory standards and data storage requirements.
This innovation increases burden on KYC and KYB processes, as verification of factual data becomes integral part of ongoing monitoring of corporate clients. Comparison with official registers requires items implementing these procedures to regularly reconcile and update their internal data.
Informing on substantial variance serves as source of additional reaction for state registers.
This allows for faster identification of inaccurate, obsolete or partial records in legal entity registers. In this way, regulators aim to improve the overall reliability of data on beneficial owners.
Current demands does not supersede other anti-money laundering and counter-terrorist financing obligations. Informing institutions are still mandatory to maintain up-to-date identification archives, conduct hazard identification, notify shady operations and big money operations, and notify contacts with individuals or organisations on sanctions lists.
Demand for matching and informing on beneficial ownership is effectively integrated into existing AML basis and doesn`t replace basic functions of compliance programme.
Introduction of data presentation on substantial variance in beneficial ownership data is important part of developing compliance infrastructure. It aims to improve quality, comparability and accessibility of information on actual owners of corporate structures. Modern requirements strengthen role of comparative analysis with government sources and increase responsibility of informing representatives for continually updating and verifying data. Taken jointly, such actions are aimed at mitigating danger of using corporate forms for illegal activities and expanding overall openness of business environment.
Material discrepancy is significant inconsistency in list of owners, absence of key persons, or conflicting notification about control over firm. Minor formatting errors or typos are not considered material. Our services include analysing official information and comparing it with public registers for correct assessment.
Yes, all supporting documents and internal calculations must be kept for period specified by regulator. Our services include organising document storage and maintaining records in accordance with requirements.
They reinforce need for regular reconciliation of customer data with official registers. ELI Canada provides support in integrating these procedures into existing investigation system and mitigating danger of non-compliance.