Ultimate Beneficial Owner (UBO) Examples
👥 Ultimate Beneficial Owner (UBO) Examples
To meet UK Anti-Money Laundering (AML) and Customer Due Diligence (CDD) obligations, we must identify and verify all Persons of Significant Control (PSCs) or Ultimate Beneficial Owners (UBOs) who ultimately own or control a company.
The following examples illustrate how to determine who needs to provide proof of ID and proof of address under the Money Laundering Regulations 2017.
Example 1: Single Director / Sole Shareholder
Structure | Details |
|---|---|
Company A | Registered in the UK |
Director: John Smith | Owns 100% of the shares |
PSC / UBO: John Smith | Controls all voting rights |
✅ Who must be verified:
John Smith (as both Director and UBO)
📋 Required: Proof of ID + Proof of Address
Example 2: Two Directors, Equal Shareholding
Structure | Details |
|---|---|
Company B | Registered in the UK |
Directors: Sarah Brown & David Green | Each holds 50% of shares |
PSC / UBOs: Sarah Brown (50%), David Green (50%) |
✅ Who must be verified:
Both Sarah Brown and David Green
📋 Required: Proof of ID + Proof of Address for each UBO
Example 3: Parent Company Ownership
Structure | Details |
|---|---|
Company C (Customer) | 100% owned by ParentCo Ltd |
ParentCo Ltd | Has three shareholders: Alice (60%), Ben (25%), Carla (15%) |
✅ Who must be verified:
- Alice (60%) — UBO
- Ben (25%) — not required (below 25% threshold)
- Carla (15%) — not required (below 25% threshold)
📋 Required: Proof of ID + Proof of Address for Alice, plus company information for ParentCo Ltd.
Example 4: Trust Ownership
Structure | Details |
|---|---|
Company D (Customer) | 100% owned by The Smith Family Trust |
Trustees: John and Emma Smith | Act on behalf of the trust |
Beneficiaries: Family members |
Settlor: John Smith |
✅ Who must be verified:
- The Settlor (John Smith)
- The Trustees (John & Emma Smith)
- Any Beneficiaries exercising control
📋 Required: Proof of ID + Proof of Address for each relevant individual, plus a copy of the Trust Deed confirming ownership.
Example 5: Non-UK Ownership Structure
Structure | Details |
|---|---|
Company E (Customer) | 100% owned by Global Holdings Ltd (incorporated in Malta) |
Global Holdings Ltd | Owned by two individuals: Maria Rossi (70%), Lars Johansson (30%) |
✅ Who must be verified:
- Maria Rossi (70%) and Lars Johansson (30%) as UBOs
- Global Holdings Ltd corporate structure documents
- Evidence of registration in Malta (e.g. Certificate of Incorporation)
📋 Required:
- Proof of ID + Proof of Address for both individuals
- Certified translation of any non-English documents if applicable
Example 6: No Single Controller
Structure | Details |
|---|---|
Company F (Customer) | 10 equal shareholders (each 10%) |
No one individual owns >25% | No PSC/UBO identified under standard definition |
✅ Who must be verified:
- The individual acting on behalf of the company (e.g. authorised representative)
- Verification based on risk-based assessment
📋 Required: Proof of ID + Proof of Address for the authorised representative
Key Takeaways
Principle | Description |
|---|---|
Threshold for PSC/UBO | More than 25% ownership or control triggers verification. |
Look-Through Approach | Keep tracing ownership until the natural person(s) with ultimate control are identified. |
Trusts and Complex Entities | Verify trustees, settlors, and controlling beneficiaries. |
Corporate Parents | Obtain documentation proving registration and ownership structure. |
No PSC Identified | Default to verifying the authorised representative or most senior controlling individual. |
🧾 All ownership structures and verification outcomes are documented and retained for a minimum of five years in line with AML regulations.
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Updated on: 05/11/2025