Certified Anti-Money Laundering Specialist Certification (CAMS) Practice Exam

In relation to beneficial ownership, what does 'ultimate control' refer to?

1. Control over day-to-day operations

2. The right to make key decisions affecting assets

3. Having the majority shareholding

4. Legal authority without actual control

The correct answer is: The right to make key decisions affecting assets

The concept of 'ultimate control' in the context of beneficial ownership pertains to the entity or individuals who possess the authority to make significant decisions that impact the company’s assets and overall strategic direction. This goes beyond merely participating in daily operations; it encompasses having the power to influence or determine how resources are utilized, the direction of the business, and critical areas such as mergers, acquisitions, and significant expenditures. The right to make key decisions is central to identifying ultimate control because it addresses the broader implications of ownership and authority, reflecting a more comprehensive understanding of how control can be exerted. Individuals or entities holding this kind of control, even if they do not have a majority shareholding, are often the ones who can impact the company most significantly. In contrast, the other options describe forms of control or influence that may not fully encapsulate the concept of 'ultimate control.' Day-to-day operational control might indicate management involvement but not necessarily the power to make governance decisions. Majority shareholding implies a level of influence but doesn’t inherently capture the decision-making rights if the shares are not exercised appropriately. Legal authority without actual control could suggest a disconnect between ownership rights and actual influence, failing to fit the definition of having the ultimate say in key business affairs.