Country-specific guidance Current

Requesting beneficial ownership information from a corporate client in the EU

The definition is set EU-wide; where that information is actually held is set by each member state.

Before you can verify who really owns or controls a corporate client, you need to request the right information from the right people. This guide sets out what the EU's beneficial ownership standard asks you to request. It is general information, not legal or compliance advice.

Action plan

1 Identify who counts as a beneficial owner under the EU standard The threshold is about shares, voting rights, or control, whichever applies, not a single simple test.

The EU's Anti-Money Laundering Regulation frames a beneficial owner of a corporate entity as a natural person who has a direct or indirect shareholding of 25% or more of the shares, voting rights, or other ownership interest, including through control of another shareholder, and, separately, anyone who exercises control over the entity through other means, even without meeting that shareholding threshold.

  • Check for direct or indirect shareholding of 25% or more of shares, voting rights, or other ownership interest
  • Include a natural person who controls a shareholder that itself holds 25% or more
  • Separately assess control exercised through other means, which can apply without any shareholding

Done when: Every individual meeting the 25% threshold, or exercising control by other means, has been identified for the request

EUR-Lex: EU Anti-Money Laundering Regulation (EU) 2024/1624, beneficial owner determination
2 Request the documents needed to verify each individual, not just a name A declared list of names is a starting point, not the evidence itself.

The Regulation expects obliged entities to obtain the information, documents, and data necessary to verify the identity of the beneficial owner, whether by taking reasonable measures to obtain it from the client or other reliable sources, or by consulting the relevant central register. Request identity evidence for each named beneficial owner alongside the ownership or control evidence that explains why they qualify.

  • Request identity evidence for each individual identified as a beneficial owner
  • Request the ownership or control evidence explaining why each individual qualifies
  • Don't accept a bare list of names without any supporting evidence behind it

Done when: Identity and ownership or control evidence has been requested for every individual named as a beneficial owner

See verifying beneficial ownership against a member state's register
3 Know that the client entity's home member state runs its own central register There is no single EU-wide beneficial ownership database; each member state maintains its own.

The EU's anti-money laundering directive requires each member state to ensure that beneficial ownership information is held in a central register, using a central database, the business register, or another central register that member state chooses. Ask a corporate client which member state its own central register entry sits in, rather than assuming a single EU-wide source will already have it.

  • Confirm which member state holds the corporate client's central register entry
  • Don't assume a single EU-wide database already contains every member state's data
  • Request the client's own register reference or extract as part of the information request

Done when: The corporate client's home member state and central register entry have been identified as part of the request