The natural person at the centre
Identifying the beneficial owner means understanding which natural person ultimately owns or controls the customer, or on whose behalf an activity is carried out. Corporate chains do not end this analysis.
Ownership and control
Ownership thresholds are a starting point, not the whole test. Voting rights, agreements, appointment powers, dominant influence and other means of control may be decisive.
Registers and independent sources
A register contributes to verification, but missing or inconsistent information requires review. The conclusion should rest on sources appropriate to risk and an understandable reconstruction of the structure.
Practical scenario
A company is 60% owned by a holding company and 40% by an individual. The holding is owned by two people, but an agreement gives one of them the right to appoint a majority of directors. The map therefore needs to show both ownership and control rights: percentages alone may lead to an incomplete conclusion.
Useful check: map the structure to the relevant natural persons and record source, percentage, control right and any inconsistency at each step.
Sources and references
Informational content. It does not replace an assessment of a specific case.
Regulation (EU) 2024/1624FATF — Beneficial ownership