The investigation involves an American company that the United States believes may be covertly owned by the Venezuelan government, making it a government-controlled corporation involved in critical operations within the US. The facts thus far:

• The Florida company, with multi-million dollar contracts, which consists of only a small office with one employee, is owned by a Dutch B.V., which is in turn listed as owned by a Netherlands Antilles N.V. located in Curacao.
  

• However, a search of the corporate registry under that company's name in Curacao, is negative.
  

• A second search, this time under the corporate number listed, uncovered yet another N.V. with the same basic name as the Florida corp.
  

• The managing directors are either old established corporate service firms, trust companies or obvious nominees.
  

• Added to the mix is a Delaware corporation. Do you get the picture by now ?
  

Two important points.
Whilst we are examining this matter, note first that US law enforcement is not fooled by complex Caribbean tax haven multi-stage non-transparent ownership schemes. Any wise corporate service professional sitting in his office in a Caribbean tax haven should know that, when issues of national security, terrorist financing or narcotics trafficking are involved, what he believes is a simple ministerial tax avoidance act might well turn into something he does not want or need: an indictment in a US District Court for conspiracy.

Second, remember, US citizens are taxed worldwide on their income, and valid European variety offshore tax avoidance schemes do not exist for Americans. Many in US law enforcement view the Caribbean tax havens as jurisdictions that exist solely to enable tax evaders and career criminals to hide their wealth. You will not know whether you have crossed over that invisible line until you are arrested upon entering the US.

Back to the story.
In the instant case, compliance officers whose banks handle certain critical defense and government contractors whose beneficial ownership must not be in foreign hands may want to obtain evidence of this US ownership, if for no other purpose than to satisfy customer identification requirements.

Though this set of facts may be a rare instance of intense US government scrutiny, compliance officers constantly see contrived schemes that are intended to obscure beneficial ownership.  It is up to you to
protect your institution, and obtain doeumentary proof of ownership sufficient to satisfy even the most difficult regulatory agency.