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.

Table of Contents

1. Example 1: Single Director / Sole Shareholder
2. Example 2: Two Directors, Equal Shareholding
3. Example 3: Parent Company Ownership
4. Example 4: Trust Ownership
5. Example 5: Non-UK Ownership Structure
6. Example 6: No Single Controller
7. Example 7: Charity – UBO-Equivalent Structure
8. Key Takeaways

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

✅ Who must be verified:

John Smith (as both Director and UBO)

📋 Required: Proof of ID + Proof of Address

Example 2: Two Directors, Equal Shareholding

✅ 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

✅ 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

✅ 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

✅ 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

✅ 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

Example 7: Ultimate Beneficial Owner (UBO) Structure – UK Charity

Charities in the United Kingdom do not have Ultimate Beneficial Owners (UBOs) in the traditional sense, as they do not have shareholders or private owners.

For AML and KYC purposes, the following individuals must be treated as “beneficial owners or persons of control”:

1. Trustees / Directors

These individuals have ultimate responsibility for the governance and operation of the charity.

• Full Name
• Date of Birth
• Nationality
• Role (e.g., Trustee, Director)
• Verification Status

2. Senior Management Officials (SMOs)

If control is dispersed and no single individual has significant control, identify and verify the senior executives:

• Chief Executive Officer
• Chief Financial Officer / Treasurer
• Chief Operating Officer (if applicable)

3. Settlor / Protector (Charitable Trusts Only)

If the charity is structured as a trust:

• Settlor (the person who originally created the trust)
• Protector (if the trust deed specifies one)

Notes

• These individuals are not “owners”; they are listed for compliance purposes only.
• Verification should be carried out in line with MLR 2017, Regulation 28 (Customer Due Diligence).
• Large charities with more than 10 trustees may apply a risk-based approach and verify only key officers.

Key Takeaways

🧾 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: 26/11/2025