A UBO — what is it again?
Ultimate beneficial owners, why they matter, and how to evidence them.
Executive summary
UBO work is about natural persons, not just company names.Declarations must be reconciled against evidence.Complex structures need a graph, not a paragraph.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.
Who this applies to
This guide is for offices onboarding companies, trusts, foundations, partnerships or other structures where a real person ultimately owns or controls the client.
- Shareholders above the ownership threshold
- Persons controlling voting rights or appointments
- Trust settlors, trustees, protectors and beneficiaries
- Nominees and intermediaries
- Foreign entities and layered ownership chains
Legal and supervisory context
The point of UBO identification is to see through legal wrappers to the individuals who ultimately own or control the relationship. A register extract is useful evidence, but it is not the whole file: the office must understand the structure, compare it with the client's declaration and resolve discrepancies.
In Belgium, the office's access to the UBO register rides on its own obliged-entity status and authenticated rights. Sceau should capture and reconcile the result; it should not pretend to resell a restricted official register.
What the office must actually do
The office should collect a declaration, map the ownership/control graph, consult the register where it has rights, upload the extract or consultation proof, and reconcile the two.
- Identify all ownership and control paths.
- Record percentages and control by other means.
- Capture documents supporting the structure.
- Consult the UBO register under the office's own rights.
- Compare official data with the client declaration.
- Raise and resolve discrepancies before acceptance or review close.
What good evidence looks like
A strong UBO file contains the declaration, graph, register consultation, discrepancy analysis, reviewer conclusion and follow-up correspondence where needed.
Common mistakes supervisors find
- Stopping at the first shareholder layer.
- Ignoring control by other means.
- Not recording why no UBO could be identified.
- Treating the register as automatically correct without reconciling it.
- Failing to update UBO evidence during ongoing monitoring.
Practical checklist
- Collect UBO declaration.
- Map ownership and control.
- Identify natural persons.
- Consult the register where required.
- Upload official extract or receipt.
- Resolve discrepancies.
- Seal the final UBO conclusion.
- Builds a UBO graph in the client file.
- Supports manual official consultation capture.
- Parses uploaded extracts where available.
- Diffs declaration against evidence.
- Creates discrepancy tasks and ledger evidence.
FAQ
Is the UBO always the shareholder above 25 percent?
Often, but not always. Control by other means can also create beneficial ownership.
Can the office rely only on the register?
No. The register is evidence to reconcile, not a substitute for understanding the structure.
What if no UBO can be identified?
The office should record the steps taken, the reason no person was identified, and the senior managing officials where applicable.
Official references
From knowledge to compliance
Reading is a start. Sceau turns these obligations into a workflow that runs itself and proves itself.
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