FIAU Revises Implementing Procedures Part I

On 27th April 2026, the FIAU issued an updated version of the Implementing Procedures Part I, herein referred to as the “IPs Part I”.

The main changes introduced to the IPs Part I are as follows:

A. Changes to the definition of a Beneficial Owner

These changes were carried out under Section 4.2.2 of the IPs Part I whereby footnote 42, which previously included an exception for Trusts and similar legal arrangements to limit themselves to consider any body acting as a beneficial owner for a Settlor, Protector and/or Trustee of a Trust, has been now removed to ensure alignment with the identification and verification requirements for beneficial owners of a Trust as set out in Section 4.3.2.5(iii).