The SEC now requires those who own or control more than five percent of the issued shares of a public company to disclose that fact.

The requirement also applies to those who are building up a stake in association with others - known as "a concert party."

It may be that UK term that has led to the SEC talking about "control intent" - a term that it seems this morning many people, including WMLR, are trying to find an authoritative definition for.

We think - and we might be wrong - that it's simply a concert party where several people are working together to secure shareholdings that are not individually subject to declaration and they are doing so with the intent to control sufficient shares to affect the company in general meeting or, even, to build up a level of shares that would, if held by one person, trigger a requirement for a takeover bid.

An example of a London Stock Exchange declaration of a concern party is here: https://www.londonstockexchange.com/news-article/TNT/form-8-dd-offeree-… . It relates to a company called Tintra PLC and it was deposited on 6th October this year.

The US SEC now requires reports of build-ups of shareholdings to be reported in five working days (it has been ten working days for several decades, before the de-materialisation of shares) and the limit has been reduced to 5% of the issued share capital.

While this is not a counter-money laundering measure, it emphasises that the percentage of (non-public) companies required to be declared under counter-money laundering laws, at 25%, is a very high percentage.