Multi-layer ownership traversal
Auto-resolves 10+ layers across jurisdictions in <90s. Handles trusts, foundations, nominees, and cross-holdings with aggregated effective percentages.
UBO verification
UBO verification across every jurisdiction that matters.
Traverse any ownership structure to natural persons in under 90 seconds. ComplianceSuite pulls from 240+ primary registries — UK PSC, US FinCEN BOI, EU BORs, ACRA, DIFC, Cyprus BOR — and auto-screens every UBO for PEP, sanctions and adverse media. Aligned to EU AMLR Art. 51–56, FATF R.24, US CTA, UK PSC and MAS Notice 626.
- 240+ registry coverage
- 10+ layer traversal in <90s
- Auto-screen every UBO
- Daily registry re-check
Definition
What is an Ultimate Beneficial Owner (UBO)?
An Ultimate Beneficial Owner is the natural person who ultimately owns or controls a legal-entity customer. Under EU AMLR and FATF Recommendation 24, an individual qualifies as a UBO where they directly or indirectly hold >25% of shares or voting rights, exercise control by other means (shareholder agreements, board composition), or — where no such person exists — sit in senior management.
UBO verification is the pillar that stops shell companies, layered structures and nominee arrangements being used to hide the true owner. It is required at onboarding, refreshed on material change, and increasingly filed to central beneficial-ownership registers such as the UK's PSC register, the US FinCEN BOI and the Cyprus BOR.
See our full UBO discovery guide, KYB platform and AML glossary.
Capabilities
What's included.
240+ registry coverage
UK PSC, US BOI, EU BORs, ACRA, Companies Registry HK, DIFC, ADGM, Cyprus BOR — plus commercial fallback for gaps.
Auto-screen every UBO
PEP, sanctions and adverse-media screening on every identified natural person — one API call, unified hit list.
Evidence-backed structure chart
Interactive chart with every edge sourced to a filing, date, and confidence score. Export-ready for audit.
Continuous UBO monitoring
Daily registry re-check. New shareholder, director, or ≥25% transfer opens a case within hours of the filing.
Regulator-defensible file
Full traversal history, source documents and analyst rationale in one exportable file — the format examiners expect.
How it works
Four steps to verified UBOs.
1. Ingest the entity
Company name + registration number → ComplianceSuite retrieves incorporation, directors, shareholders and structure from the primary registry.
2. Traverse ownership
Recursively resolve each corporate shareholder in its own jurisdiction until every branch terminates in a natural person, trust or a documented dead-end.
3. Screen every UBO
Each identified natural person runs through PEP, sanctions and adverse-media screening in one call. Hits open cases with tiered EDD workflows.
4. Monitor continuously
Daily registry re-check across all resolved entities. New UBO, director change, or ≥25% share transfer triggers a case within hours.
Example
Three structures, three resolution paths.
| Complexity | Scenario | Resolution |
|---|---|---|
| Simple — Single-layer LLC | US LLC with two individual members at 60% / 40% | Both members identified as UBOs, ID-verified, PEP/sanctions/media-screened. Resolution time: <15 seconds. |
| Medium — Cross-border holding | UK operating co owned by Cyprus holdco (100%) owned by two individuals at 70% / 30% | Traversal resolves 3 layers, 2 jurisdictions; both natural persons identified as UBOs with 70% / 30% effective ownership. Resolution time: ~45 seconds. |
| Complex — Trust + foundation | UAE operating co owned by BVI holdco owned by Jersey trust with Liechtenstein foundation as protector | Registry-only traversal terminates at the trustee and protector; enhanced UBO declaration requested from customer per FATF R.24; MLRO sign-off required. Case opens with structured EDD template. |
Regulatory coverage
UBO obligations across major regimes.
| Regime | Scope | Requirement |
|---|---|---|
| EU AMLR (Reg. 2024/1624) Art. 51-56 | EU 27 | Identify UBOs at ≥25% threshold (control tests where lower); verify via authoritative source; central BOR filing; refresh on change. |
| FATF Recommendation 24 | Global standard | Adequate, accurate and up-to-date beneficial-ownership information on legal persons and arrangements; multi-pronged approach combining registries and CDD. |
| US FinCEN Corporate Transparency Act | United States | Beneficial Ownership Information (BOI) filing for most US and foreign entities registered in the US. Reporting company identifies each beneficial owner (≥25% or substantial control). |
| UK PSC Regime (Companies Act 2006) | United Kingdom | People with Significant Control register: 25% shares, 25% voting rights, right to appoint/remove majority of directors, or significant influence/control. Updated at Companies House. |
| MAS Notice 626 §6 | Singapore | Identify UBOs and take reasonable measures to verify identity using reliable independent sources; risk-based enhanced measures for complex structures. |
| Cyprus BOR (Directive K.D.P. 112/2021) | Cyprus | Central beneficial-ownership register maintained by the Registrar of Companies; updated within 45 days of change; obliged entities must consult in addition to independent verification. |
Frequently asked questions.
What is UBO verification?
Ultimate Beneficial Owner (UBO) verification is the process of identifying and verifying every natural person who ultimately owns or controls a legal-entity customer — typically anyone holding ≥25% of shares or voting rights, or exercising control by other means. It is mandatory under FATF Recommendation 10 & 24, EU AMLR, FinCEN CTA, UK PSC, and equivalent regimes.
What counts as an UBO?
Under EU AMLR and FATF: any natural person who directly or indirectly holds >25% of ownership or voting rights; any person who exercises control via shareholder agreements, board composition, or other means; and, where no such person is identifiable, the senior managing official. UK PSC lowers the threshold to 25% including significant influence or control.
How do you trace UBOs across complex structures?
ComplianceSuite auto-traverses shareholder chains across 240+ corporate registries, resolves trusts and foundations, aggregates cross-holdings, and calculates effective ownership percentages down to natural persons. Structures with 5+ layers across multiple jurisdictions typically resolve in under 90 seconds.
Which registries do you use?
Primary sources including UK Companies House PSC, US FinCEN BOI, EU beneficial-ownership registers (per Member State), Cyprus BOR, DIFC BOR, Singapore ACRA, Hong Kong CR, UAE beneficial-ownership registers, plus commercial data (Dun & Bradstreet, Moody's Orbis) for coverage gaps.
How do you handle nominee shareholders?
Nominee arrangements, bearer shares (where still permitted) and trust vehicles are flagged for enhanced review. ComplianceSuite requests declaration of the true beneficial owner, verifies against known nominee-service providers, and applies EDD if control cannot be resolved to a natural person.
Do you screen every UBO for PEP and sanctions?
Yes. Every identified UBO is automatically screened for PEP status (240+ jurisdictions), sanctions (OFAC, UN, EU, UK, HMT and 1,500+ lists) and adverse media in a single call — no separate orchestration needed.
What if the ownership structure changes?
With perpetual KYC enabled, corporate registry filings across 240+ jurisdictions are monitored daily. New director appointments, share transfers, and beneficial-ownership updates trigger a case within hours of the source publication.
Is UBO verification the same as KYB?
UBO verification is a critical component of KYB (Know Your Business) — but KYB is broader. KYB also covers entity legitimacy (existence, registration, licensing), directors, group structure, financial standing, sanctions on the entity itself, and business-purpose verification.
Traverse your hardest ownership structure.
Send us the trickiest corporate customer in your book. We'll resolve the UBO tree live and show every source, screening hit and confidence score.
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