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Shareholders, UBOs, and control persons

Business onboarding reviews direct owners, indirect owners, UBOs, control persons, directors, officers, and authorized signers. These roles can overlap, but they are not interchangeable.
Ownership and control requirements vary by review. Follow the current task for the facts and evidence required for a specific customer and capability.

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Role distinctions

  • A direct owner holds an interest in the business being onboarded.
  • A UBO is an individual reached through direct or indirect ownership or control at the policy threshold.
  • A control person directs or significantly influences the business, regardless of ownership percentage.
  • A director serves in a governance role.
  • An authorized signer has authority to act for the company.
Record each applicable role. Do not infer that a director is a UBO, that every UBO is a director, or that a signer is necessarily a control person.

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UBO definition and threshold

An Ultimate Beneficial Owner is an individual who directly or indirectly owns or controls 25% or more of the business. The policy threshold is 25% in all supported countries.

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Who must be identified

Identify:
  • Any individual who owns 25% or more
  • Control persons, regardless of ownership percentage
  • Directors with significant influence
An owner below 25% who has no significant control and is not a director may not need to be identified as a UBO. This does not remove the requirement for ownership evidence to account for the complete structure. If no individual owns 25% or more, identify at least one control person, typically the CEO or managing director.

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Ownership chains

When another entity owns the business, provide ownership evidence for that parent and continue through every parent entity until you reach the individual UBOs. The corporate-structure evidence must account for 100% of ownership, including interests below the UBO-identification threshold.

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Evidence and current API resources

Current API implementations represent owners and control actors as related-party resources under the business customer: When a business capability needs beneficial-owner evidence and no related party qualifies yet, the business intake task carries a resource_reference requirement with qualification: "beneficial_owner". A related party qualifies when it is an active person party with declared beneficial ownership or a supplied ownership percentage of at least 25. Creating or updating a qualifying party meets that requirement; archiving the last qualifying party reopens it. See the beneficial-owner prerequisite for the full mechanics. Use the current task to determine which parties and roles to provide. API/resource facts and supporting document evidence may both be required. A cap table, ownership agreement, ledger, organization chart, or attestation does not replace current related-party facts when the task requests them, and resource facts do not replace document evidence when the task requests a file. See business onboarding for related-party mechanics and document requirements for ownership and governance evidence.

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Identity evidence

A current task may request government-issued identity evidence and proof of address for an owner, UBO, director, control person, or signer. Policy categories include passports, national identity cards, driver’s licenses, and proof of address. Upload only the evidence requested by the current task through the Integration Documents guide.