Ultimate beneficial owner (UBO)

Ultimate beneficial owner

The natural person who ultimately owns or controls a customer: in Hong Kong, more than 25% of the shares or voting rights, or ultimate control.

The ultimate beneficial owner is the person at the end of the ownership chain. Schedule 2 of the AMLO defines a beneficial owner of a corporation as an individual who owns or controls, directly or indirectly, more than 25% of the issued share capital or of the voting rights, or who exercises ultimate control over its management. For a partnership the test is more than 25% of the capital, profits or voting rights. For a trust it is a beneficiary or class of beneficiaries entitled to a vested interest in the trust property, the settlor, the trustee, a protector or enforcer, and anyone with ultimate control over the trust.

The threshold differs by place. Mainland China's beneficial owner measures (PBOC and SAMR Order [2024] No. 3) use 25% or more. The EU uses 25% or more with indirect holdings multiplied along each chain. The UAE's federal rule is 25% or more. Singapore's MAS notices set no fixed figure and give more than 25% as an example. Our regulation pages set each out.

Why it matters

A company's register shows its shareholders, who are often other companies. The UBO is only found by following each layer, sometimes through Mainland, BVI and Cayman entities, until a natural person appears. Hong Kong companies must keep this information in a significant controllers register, but it is not public.

How Fill Easy relates to it

UBO tracing can be added to any CorpVerify order. Shareholders are followed through every corporate layer, including multi-layer Mainland structures and offshore holding companies, and the beneficial owners are named in the summary with the registry documents attached.

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