{"id":10949,"date":"2026-04-09T09:15:08","date_gmt":"2026-04-09T09:15:08","guid":{"rendered":"https:\/\/www.amlcc.com\/?p=10949"},"modified":"2026-04-09T09:15:08","modified_gmt":"2026-04-09T09:15:08","slug":"whats-an-opaque-ownership-structure","status":"publish","type":"post","link":"https:\/\/www.amlcc.com\/bm\/whats-an-opaque-ownership-structure\/","title":{"rendered":"What’s an opaque ownership structure?"},"content":{"rendered":"\n

What’s an opaque ownership structure?<\/h1>\n\n\n
\"Richard<\/div>
Richard Simms<\/span>

Director and Founder of AMLCC and AMLCC Consult<\/h3><\/div><\/div><\/div><\/div>\n\n\n
\"What's<\/figure><\/div><\/div>\n\n\n\n
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An opaque ownership structure is one where the identity of the person who ultimately owns or controls a legal entity is hidden, layered or difficult to establish. The entity itself may be entirely legitimate but the arrangement makes it hard to answer a fundamental question: who is really in charge, and who benefits?<\/p>\n\n\n\n

For AML regulated professionals, this matters because opaque structures are one of the most commonly used methods for moving and concealing criminal funds. Understanding what they look like, why they present risk and what the regulations require you to do about them is central to applying effective customer due diligence.<\/p>\n\n\n\n

Why is opaque ownership a money laundering risk?<\/strong><\/strong><\/strong><\/strong><\/h2>\n\n\n\n

Criminals exploit legal entities precisely because they can place distance between themselves and their assets. A company, trust or similar arrangement can hold property, open bank accounts, enter contracts and move money, all without making the underlying individual immediately visible.<\/p>\n\n\n\n

FATF<\/a> (the Financial Action Task Force), whose standards underpin UK AML law, identifies the misuse of legal persons and legal arrangements as one of the primary methods used to launder criminal proceeds. <\/p>\n\n\n\n

Its Recommendations 24 and 25 set global standards requiring countries to ensure that accurate, adequate and up-to-date beneficial ownership information is available to competent authorities. The UK’s Money Laundering Regulations 2017<\/a> (as amended) (MLRs) give those standards domestic legal effect.<\/p>\n\n\n\n

The UK’s National Risk Assessment 2025<\/a> (NRA) is direct on this point. Complex corporate structures appear in most case studies and typologies for money laundering<\/a>, and the risk of money laundering through the misuse of UK corporate structures remains high. <\/p>\n\n\n\n

The NRA also notes that kleptocrats, organised criminals and sanctions evaders frequently exploit trusts and opaque corporate structures to sidestep UK transparency rules.<\/p>\n\n\n\n

What makes an ownership structure opaque?<\/h2>\n\n\n\n

Opacity can be introduced in several ways, and they are often used in combination. Common features include:<\/p>\n\n\n\n