A UBO — what is it again?

The ultimate beneficial owner is the natural person who ultimately owns or controls a client — typically through a shareholding above 25%, or through control by other means. The point of AML is to see past the company to the real people behind it.

Obliged entities must identify the UBO, take risk-based measures to verify them, and — as obliged entities — consult the national UBO register and reconcile what it says against what the client declared. A mismatch is a red flag to resolve, and to record.

Complex structures, nominees and foreign layers make this harder and push a file toward enhanced due diligence. Mapping the ownership graph and storing the register consultation as dated evidence is the difference between a defensible file and a finding.