⚖️ Legal notice
This checklist is intended solely for general information purposes and does not constitute legal, tax or compliance advice. Although the content has been carefully compiled on the basis of current laws and regulations, no rights may be derived from it. Always consult a qualified adviser for your specific situation.
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UBO analysis and ownership investigation
Sanctions list screening
Structure risk assessment
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STEP 1 · Assess the ownership structure
Is the ownership structure simple to understand and explainable in a maximum of 3 to 4 layers?
Does each structural layer have a demonstrable tax, legal or organisational function?
Are there entities in secrecy jurisdictions (Cayman Islands, Panama, BVI, Delaware, Nevada) — and is there a business justification for that choice?
Are there entities in Free Trade Zones or offshore jurisdictions such as Dubai (JAFZA/DIFC), Hong Kong, Malta or the British Virgin Islands?
Does the entity (or an entity in the structure above) make use of bearer shares?
Is there an Anglo-Saxon trust, Liechtenstein Foundation, STAK or comparable vehicle — and are the beneficiaries identifiable?
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More than 4 layers without explanation = elevated risk. Each purposeless layer increases the burden of proof for the client.
STEP 2 · Identify the UBO
Can you identify the UBO (Ultimate Beneficial Owner) as a specific natural person — not just a company name?
Is the UBO registered in the UBO register of the country of incorporation?
Are there interests of just below 50% across multiple entities simultaneously — which may indicate deliberate fragmentation to circumvent sanctions screening?
Are there indirect control mechanisms such as management contracts, loans or voting rights arrangements that mask actual control?
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A company name as UBO is insufficient. A UBO investigation does not stop at the first legal entity.
STEP 3 · Assess the directors and governance
Do the directors have demonstrable relevant experience matching the company's activities?
Are the directors or shareholders professional nominees registered at dozens or hundreds of other companies? This points to a nominee structure with no real decision-making power.
Are directors resident in an EU high-risk country or secrecy jurisdiction?
Is there a nominee director or nominee shareholder present — a paid third party who formally signs but has no actual control?
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A director with no relevant expertise, resident in a high-risk country or running hundreds of companies is a classic nominee structure signal.
STEP 4 · Check the business address and activities
Does the business address match the activities — or is it a letterbox address shared with dozens of other entities?
Does the company have a visible online presence appropriate to the scale and nature of its activities?
Is there demonstrable staff, an office and business turnover in the country of incorporation (substance)?
Does the structure match the company's activities — or is the structure more complex than the business operations justify?
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A company with no substance in its country of incorporation is a strong red flag, regardless of how professional the paperwork looks.
STEP 5 · Test the economic rationale
Do you yourself understand how the complete ownership structure works — and can you explain who ultimately benefits?
Can you explain the structure to your bank, accountant or regulator without it sounding forced?
Is there no time pressure? Pressure to act quickly without space for questions or documentation is a classic manipulation signal.
Is none of the entities or persons involved on a sanctions list (EU FSF, OFAC SDN, UK Sanctions List)?
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If you cannot explain the structure, you cannot defend it either. Document all findings in writing in a file.
💬 The test question you must always ask:
Can the client provide a written explanation that logically justifies the structure from a tax, legal or organisational perspective? If they cannot or will not, the outcome of the investigation is by definition insufficient — regardless of how legitimate the structure appears at first glance.
🚩 STOP — start in-depth investigation if:
- ⛔The structure has more than 3 to 4 layers without demonstrable logic.
- ⛔There is an entity in a secrecy jurisdiction or Free Trade Zone without business justification.
- ⛔There are bearer shares, a STAK, trust or Liechtenstein Foundation without identifiable beneficiaries.
- ⛔The director is a nominee: no relevant expertise, resident in a high-risk country, or registered at dozens of other companies.
- ⛔A party's interest is deliberately kept just below 50% across multiple entities simultaneously.
- ⛔The client cannot or will not provide a written explanation of the structure.
- ⛔There is pressure to act quickly without space for verification.
Unsure about a client or structure?
UBO investigation
Sanctions screening
Structure analysis
👉 Request a KYC report →
Bank-grade KYC report · Within 48 hours · Professional & independent