didn't check all filings but saw Poulton listed as attny for BMBM as far back as 2007. Guess he hung around through it all but we may know more about his involvement, seed money, holder...soon:
Determining beneficial ownership information is a requirement of the 4th AML Directive in Europe and different jurisdictions are passing[when?] enabling laws to enforce reporting requirements.
In the US, similar beneficial ownership disclosures are a part of the FinCEN Customer Due Diligence Final Rule, which takes effect May 11, 2018.
Generally, there are four steps required to determine the beneficial ownership:
Identify and verify an accurate company record such as information regarding register number, company name, address, status, and key management personnel
Determine the entities or natural persons who have an ownership stake, either through direct ownership or through another party
Calculate the total ownership stake, or management control, of any natural-person and determine if it crosses the threshold for UBO (ultimate beneficial owner) reporting
For all individuals that are determined to be a UBO, perform AML/KYC checks.[4]
I agree Quin, appears to be a reputable firm - should know the ropes in the US for sure!
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