Beneficial Owners (UBOs)

Beneficial owner identification is a critical component of KYB, required by AML regulations worldwide. TrustGate helps you identify, verify, and screen individuals who ultimately own or control a company.

What is a Beneficial Owner?

A Beneficial Owner (also called Ultimate Beneficial Owner or UBO) is a natural person who:

• Owns 25% or more of the company (directly or indirectly)
• Controls 25% or more of voting rights
• Exercises control through other means (board control, veto rights)
• Is a senior managing official (if no UBO meets above criteria)

UBO Identification

Add UBOs to a Company

curl -X POST https://api.bytrustgate.com/v1/companies/{company_id}/ubos \
  -H "Authorization: Bearer YOUR_API_KEY" \
  -H "Content-Type: application/json" \
  -d '{
    "first_name": "John",
    "last_name": "Doe",
    "date_of_birth": "1970-01-15",
    "nationality": "USA",
    "country_of_residence": "USA",
    "ownership_percentage": 40.0,
    "ownership_type": "direct",
    "voting_percentage": 40.0,
    "roles": ["director", "shareholder"],
    "address": {
      "line1": "123 Main Street",
      "city": "San Francisco",
      "state": "CA",
      "postal_code": "94102",
      "country": "USA"
    }
  }'

Ownership Types

Type	Description	Example
direct	Directly owns shares	Person owns 30% of Company A
indirect	Owns through another entity	Person owns Company B which owns 30% of Company A
control	Control without ownership	Board chairman with veto rights

UBO Roles

Role	Description
shareholder	Owns shares in the company
director	Member of the board
officer	Executive officer (CEO, CFO, etc.)
signatory	Authorized signatory
legal_representative	Legal representative

UBO Verification (KYC)

Each UBO should undergo individual KYC verification. Link a UBO to an existing applicant:

curl -X PATCH https://api.bytrustgate.com/v1/companies/{company_id}/ubos/{ubo_id} \
  -H "Authorization: Bearer YOUR_API_KEY" \
  -H "Content-Type: application/json" \
  -d '{
    "linked_applicant_id": "550e8400-e29b-41d4-a716-446655440000"
  }'

Or create a new applicant for the UBO:

# 1. Create applicant for UBO
applicant = create_applicant({
    "first_name": ubo["first_name"],
    "last_name": ubo["last_name"],
    "date_of_birth": ubo["date_of_birth"],
    "nationality": ubo["nationality"],
})

# 2. Run KYC verification
upload_document(applicant["id"], "passport", passport_file)
run_screening(applicant["id"])

# 3. Link to UBO record
link_ubo_to_applicant(company_id, ubo_id, applicant["id"])

UBO Verification Status

Status	Description
pending	UBO identified, not yet verified
in_progress	KYC verification in progress
verified	KYC complete, identity confirmed
failed	KYC verification failed
linked	Linked to verified applicant

Complex Ownership Structures

Indirect Ownership

When ownership is through intermediate entities:

Person A (UBO)
    └── 100% owns Company B
              └── 40% owns Company C (target)

Person A is UBO of Company C with 40% indirect ownership

Multiple Layers

TrustGate supports documenting multi-layer structures:

{
  "first_name": "John",
  "last_name": "Doe",
  "ownership_percentage": 30.0,
  "ownership_type": "indirect",
  "ownership_chain": [
    {
      "entity_name": "Holding Company Ltd",
      "ownership_percentage": 100.0,
      "jurisdiction": "BVI"
    },
    {
      "entity_name": "Investment Corp",
      "ownership_percentage": 60.0,
      "jurisdiction": "Delaware"
    }
  ]
}

UBO Screening

Screen all UBOs against sanctions and PEP lists:

# Screen individual UBO
curl -X POST https://api.bytrustgate.com/v1/screening/check \
  -H "Authorization: Bearer YOUR_API_KEY" \
  -H "Content-Type: application/json" \
  -d '{
    "name": "John Doe",
    "date_of_birth": "1970-01-15",
    "country": "USA",
    "check_types": ["sanctions", "pep"]
  }'

Regulatory Requirements

Jurisdiction	UBO Threshold	Requirements
USA (FinCEN)	25%	CDD Rule requires UBO identification
EU (AMLD)	25%	Must access UBO registers
UK	25%	PSC Register requirements
Singapore	25%	ACRA requirements
FATF	25% (recommended)	Risk-based approach

Best Practices

1. Complete coverage: Identify ALL 25%+ owners
2. Verify identity: Run KYC on each UBO
3. Screen thoroughly: Check sanctions, PEP, adverse media
4. Document structure: Record ownership chains
5. Ongoing monitoring: Re-verify annually or on changes
6. Senior management: If no 25%+ owner, identify senior management

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Next Steps

• Company Verification - Verify the company itself
• Company Screening - AML screening
• API Reference - Full API documentation