UBO & KYC

How to run a UBO discovery process

A step-by-step approach to identifying ultimate beneficial owners across layered ownership structures, and documenting the result.

The FLIORE Compliance Desk

Family-office compliance research

8 min read

Updated 1 July 2026

Key takeaways

UBO discovery combines legal analysis, document collection, verification and escalation.
Trace through every layer until you reach natural persons.
Where records conflict, resolve or document — never simply proceed.

Map the structure

Start from the entity and map every shareholder, member or beneficiary. Where an owner is itself a legal entity, expand it. Continue until every branch ends in a natural person or a documented dead end.

Collect evidence

For each identified person, gather evidence of both ownership and control: shareholder registers, trust deeds, articles, and identity documents. Self-declarations alone are not enough — corroborate against independent sources where possible.

Verify and screen

Each UBO should be verified against reliable sources and screened for sanctions, PEP status and adverse media. This is not a one-time step: ownership changes, so the file needs periodic refresh.

Resolve conflicts

Where declarations, documents and registry data disagree, the file should not move forward. The discrepancy must be resolved, escalated, or documented with a clear rationale.

FAQ

How deep must I trace?

Until you reach natural persons or a defensible stopping point — layers do not excuse you from the duty.

What if a register is unavailable?

Rely on a multi-source approach; EU register access is now often restricted to legitimate interest.

Sources

FATF Recommendation 24/25 — Beneficial ownership of legal persons and arrangements.
EU AMLA — Supervises access and harmonisation from 2025.

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