How UBO identification works
An ultimate beneficial owner (UBO) is the natural person who ultimately owns or controls your client. You build the structure around the client in the case file, and RiskResolve works out the interest through the share chain.
A person with 25 percent or more gets a possible UBO hint. You decide who you record as UBO, with type, ownership and voting percentage. You then screen every UBO, and every change to an entity goes into the activity log.
The UBO declaration is one of the standard forms your client fills in through the client portal. A company report shows directors, shareholders and the group structure. You can also add custom fields to files and entities, and filter on them later.
What the Wwft asks of UBO identification
Article 3(2)(b) Wwft requires you to identify the ultimate beneficial owner, take reasonable measures to verify their identity and understand the client’s ownership and control structure.
Who counts as UBO is set out in Article 3 of the Wwft Implementation Decree 2018. For a Dutch BV or NV it is the natural person holding, directly or indirectly, more than 25 percent of the shares, voting rights or ownership interest. If nobody is found after exhausting all means, the directors count as UBO, the so-called pseudo UBO.
Frequently asked questions
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