Schedule 2, paragraph 6 describes a beneficial owner as meaning someone, for example, who
“has the right to exercise, or actually exercises, significant…control over”
an “entity”. However, part 4 of schedule 2—on beneficial owners exempt from registration—goes on to describe such a person as someone who has
“the right to exercise, or actually exercises, significant influence or control over”
an “entity”. It may be that that apparent confusion is dealt with in part 3 of schedule 2, which deals with an entity
“subject to its own disclosure requirements”,
but it is not at all clear whether someone has to be a registrable beneficial owner, or whether they are exempt for precisely the same criteria.