UBO Registry Data: A Global Guide to Beneficial Ownership in 2025
One weak link in an anti-money laundering system can break your business – and identifying the ultimate beneficial owner(s) (UBO) is a key line of defence. Banks know this, with 30% of respondents in a PwC survey saying obtaining beneficial ownership information is the most crucial component of their customer due diligence process.
When Danske Bank was found to have facilitated money laundering, it was given a €2 billion fine. Then its share price dropped by 50%. 28,000 customers walking away. Investors sued.
But that was seven years ago. In 2025, the authorities are fining institutions for weak AML systems even without proven money laundering cases, as with recent cases such as Revolut, Starling Bank, and Monzo. In other words, the regulatory bar has been raised significantly.
But how do you balance thorough due diligence with operational efficiency? How do you navigate the complexity of global UBO requirements without creating friction that drives customers away?
This comprehensive guide examines the current UBO landscape, explores the reliability challenges of registry data, and provides practical insights for building robust verification systems that protect your institution while maintaining a competitive advantage.
What is an Ultimate Beneficial Owner (UBO)?
According to the Financial Action Task Force (FATF) in March 2023, the ultimate beneficial owner is the natural person – a human, not a business – who derives the most benefit from a transaction or has the most control over a business arrangement.
The most common way this works in practice is that the UBO is the person who holds more than 25% of shares or voting rights. However, jurisdictions interpret this differently.
The European Union: The EU's 6th Anti-Money Laundering Directive (6MLD) allows member states to implement lower UBO thresholds, down to a minimum of 15%, for high-risk sectors.
The USA: The U.S. Corporate Transparency Act (CTA) has a similar 25% ownership threshold combined with a "substantial control" test, which captures individuals who exercise significant influence over an entity without necessarily meeting the ownership criteria.
Key distinction: A legal owner is a person, company or other entity that owns a company. In contrast, an ultimate beneficial owner is a natural person (human being) who ultimately owns or controls a company - typically through direct or indirect ownership of shares, or voting rights.
The FATF’s rule is not universal and can be subject to significant variation, which makes identifying the UBO extremely complex. Generally, regulated entities set thresholds based on risk level. Private banks and wealth management funds, for instance, set lower thresholds for this reason.
Why is it important to verify UBOs?
Verifying the ultimate beneficial owner of a legal entity is a standard legal requirement for regulated institutions, because the authorities cannot prevent financial crime if they don’t know who controls or profits from an entity.
This is why businesses found to have been unknowingly complicit in money laundering suffer dire consequences.
Case Study: Danske Bank
In 2017, it emerged that Danske Bank’s Estonian branch had enabled the flow of €200 billion in suspicious transfers, the bank having failed to properly verify the UBOs of multiple high-risk business accounts – some of whom were linked to the Russian government.
Regulatory Fine: The authorities fined it over €2 billion.
Reputational Damage: Many of the bank’s leading bankers were charged for failing to prevent money laundering.
Fall in Share Price: Its value plummeted by more than 50%.
Lawsuits from Investors: Leading investors sued the bank for lost equity.
Loss in Customers: 28,000 private customers closed their accounts.
This story isn’t unique to Danske Bank. As research by Themis shows, share prices consistently plummet following reputational damage resulting from money laundering scandals.
The AML Landscape in 2025
The authorities no longer simply fine regulated institutions for facilitating money laundering. They also fine them for having weak AML systems that are vulnerable to financial crime.
Revolut’s most recent fine in April 2025 is a good example. No instances of money laundering were found. However, the fintech was still fined for weak AML controls conducive to money laundering.
The same is true for Starling Bank and Monzo. In 2024 and 2025, respectively, both fintechs were fined by Britain’s Financial Conduct Authority (FCA) for “lax” AML controls, which enabled the two fintechs to onboard high-risk customers, including customers with registered addresses at Buckingham Palace and Number 10 Downing Street.
Bottom Line: Accurately verifying UBOs protects regulated institutions from fines, reputational damage, investment loss, lawsuits, and consumer dissatisfaction.
What Data Should Be Used For UBO Verification?
To avoid fines, the Financial Action Task Force (FATF) has recommended since March 2023 that financial institutions use a multi-pronged approach comprising "several sources of information" – rather than relying on single data points:
Information from clients
Official company registers or UBO registers
Other government databases – including taxpayer, land and population registers.
Documentation: As the 2023 guidance states, documents such as share certificates, shareholder registers and board resolutions are essential.
FATF Guidance is Clear: Regulated entities must use multiple official sources of company information – not just UBO registry data. It is recommended that financial crime professionals cross-reference UBO registry data with underlying shareholder data from automated verification solutions, such as UBO Verify.
Is UBO Registry Data Reliable?
The effectiveness of a UBO program is directly tied to the quality of its data. However, while official government registries are a necessary and authoritative source, they’re not uniformly reliable.
Self-Reporting Systems: As OpenOwnership research shows, countries rely on companies to truthfully disclose beneficial ownership information, which means bad actors can submit deliberate falsehoods.
Limited Cross-Checking: In most countries, there is little official cross-checking of UBO information.
Accidental Errors: Marginally incorrect spelling, dates and addresses in data entry.
Varied Data Verification: Some countries don’t verify UBO registry data, while others require notarised declarations.
Stale Data: The authorities rarely keep UBO registers up to date, often, in the case of UK Companies House, relying on regulated institutions to report discrepancies with their own findings. In the case of the Netherlands, it’s suspected that financial regulators don’t have the resources to investigate.
UBO Data Quality Differs Per Country
Some countries do verify ultimate beneficial ownership registry data, mainly by ensuring the UBO declarations follow a predictive pattern.
Belgium prevents the registration of more than 100% of shares or voting rights (as this would be impossible).
In China, UBO data is cross-checked with other government databases
In Denmark, UBO data is cross-checked with government registers such as the civil register and the address register.
In LMICs, such as Slovakia, public notaries, lawyers, and banks are responsible for checking UBO information.
Some countries have limited UBO verification. The UK has a public register, but there’s a lack of enforcement in the filing of Person of Significant Control (PSC) reports. While in Panama, the data relies on the self-reporting of a resident agent, which can introduce errors or deliberate misrepresentations.
This is why the reliance on any single data source, even an official one, introduces a significant risk.
Where Can UBO Registry Data Be Accessed?
Per the FATF’s recommendations, 99 countries have implemented ultimate beneficial ownership registers. However, they differ on how they collect UBO data and who can access it.
Public Registers: Open versus Closed
As a report by Open Ownership shows, the need to access multiple, global registers is key in exposing complex transnational ownership structures. One investigative journalist said, “You will always need to go to another country’s register.” However, most UBO registers are closed.
The EU: While the EU’s 5th Anti-Money Laundering Directive required member states to establish publicly-accessible beneficial ownership registers, only one-third have maintained public access to these registers.
The US: In March 2025, Donald Trump overturned the requirement, per the Corporate Transparency Act, for US-registered businesses to report their ultimate beneficial owner, because it didn’t benefit the “public interest”.
Tax Havens: Low-tax jurisdictions like the British Virgin Islands have routinely failed to provide access to investigators to their UBO register.
UBO Data API Access:
Some UBO registries, such as the UK, provide direct API access to their UBO data.
The UK Companies House API, for example, is a RESTful API that allows developers to retrieve public company data, including PSC information, using simple GET requests.
However, it requires significant in-house development to build, maintain, and normalise data from multiple, non-standardised registries. Using the global business register gives you access to 300+ official corporate registers in one place, in real time.
Private Registers
The Asia-Pacific region has a preference for restricted access similar to the post-CJEU EU model.
Singapore: ACRA mandates that companies maintain a non-public Register of Registrable Controllers (RORC) that is accessible to law enforcement agencies for investigations.
Hong Kong: Companies Ordinance requires companies to maintain a non-public Significant Controller Register (SCR), only accessible to local law enforcement, which must be verified and retained by financial institutions for a minimum of five years.
These examples illustrate a crucial point: a bank's global UBO strategy must be built on the premise that most official data will not be publicly available.
It needs a multi-pronged approach that leverages commercial data providers and robust internal controls.
The Importance of Data Intermediaries in Filling Gaps
Open Ownership, an international charity that advises governments on beneficial ownership reforms, believes data intermediaries such as Kyckr are “a crucial part of the data-use ecosystem” owing to the limited access given by UBO registers.
Accessibility: Help users access shareholder data to verify beneficial owners instantly.
Data: Provide clean, combined and structured data
Global Reach: Combine BO information from multiple jurisdictions with other information, such as official registry shareholder data.
Technology: Provide API integrations that enable faster entity resolution.
Regulations: Under British law, firms must cross-reference the Person of Significant Control with underlying shareholder data.
This enables instant entity resolution, often by cross-referencing historical BO information, which might not appear in official registers.
Automated UBO Verification Powered by Official Sources
Identifying UBOs with primary source company data is important if you don’t want to get fined. However, access to UBO registry data is limited and, even then, the data isn’t always reliable.
This poses a problem for financial crime professionals; UBO verification becomes time-consuming, leading to slow client onboarding and high rates of attrition. The question then is, how can you faithfully fulfil your compliance obligations while not sacrificing customers?
Kyckr’s UBO Verify solution instantly verifies UBOs using official shareholder data, pulled from 300+ official registers in real time.
It matches a company’s shareholders to other entities and persons (across borders) using an index of registry data.
Retrieves the next layer of data if a match is found.
UBOs are calculated according to a percentage ownership threshold set by users.
Within seconds, you are presented with the calculated UBOs along with a structured data set, a graph visualisation, and a PDF report.
“UBO Verify was a game-changer,” said Spektr co-founder Jeremy Joly. “Our customers need ownership graphs, and Kyckr’s incredibly detailed UBO report helps them unravel complex ownership structures quickly — sometimes, instantly.”
Book a demo to find out more.
