Beneficial ownership: what Seychelles expects you to keep

There is a persistent assumption that offshore jurisdictions hide ownership from everyone. What Seychelles actually does is narrower and more defensible: the beneficial ownership record for a specified entity is not published, but it must exist, be accurate, and be held by the entity's licensed registered agent where it can be produced.

Who counts as a beneficial owner

• Any individual holding or controlling a significant share of the entity, directly or through other companies.
• Any individual able to exercise significant influence over its management.
• Where no individual is identifiable, the person who holds a senior management position.
• For trusts and foundations, the settlor or founder, the trustees or council, the protector if any, and the beneficiaries or class of beneficiaries.

What the file has to contain

Identification and verification for each individual, a passport and a current proof of address, plus the evidence that supports the structure. In practice that means the ownership chart through every intermediate layer, and an explanation of why each layer exists. Source of funds addresses the money going into the entity; source of wealth addresses how the individual came to have it in the first place. Those are different documents and examiners treat them as such.

Where it goes wrong

• A nominee is appointed and the declaration of trust is never signed, leaving the register technically accurate and practically meaningless.
• An entity is acquired second hand with a file that has no history behind it.
• Ownership changes on a handshake and the record is never amended.
• The entity is moved to a new provider and the registers arrive incomplete.

Keeping it usable

Treat the record as a living document rather than an onboarding step. Refresh the evidence on a diarised cycle, amend it whenever the structure moves, and keep it with the statutory registers at the registered office. When a correspondent bank or an auditor asks, and one will, the answer should be a file, not a reconstruction.