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AMLR 2027 guide

Ownership and control

Identify customers and their ultimate beneficial owners before screening. A company can be affected by sanctions through its owners, and a person can control a company without owning most of it.

Check the owners’ combined shares

Covered by the regulation

A company can be affected by sanctions through its owners. Article 20(1)(d) includes ownership above 50%, held by one listed owner or several together.

Two owners’ shares added together
Listed owner A
30%
Listed owner B
25%
Combined share
55%

Check whether the combined 55% share brings the company within the applicable sanctions rules. Similar names alone do not prove that these are the listed owners.

Illustrative example. Assess the documents and applicable rules in each case.

Two listed owners with shares of 30% and 25% hold 55% together. Check who the owners are, verify their shares and assess the sanctions rules that apply.

Read Article 20(1)(d) in the regulation

Check who controls the company

Covered by the regulation

A person can control a company without owning most of it. Article 20(1)(d) covers control as well as ownership.

Control without owning most of the company
  • Share of the company: 30%
  • Right to appoint most of the board

This right may indicate control. Check the documents and applicable rules before making a decision.

Illustrative example. Assess the documents and applicable rules in each case.

For example, someone with a 30% share might have the right to appoint most of the board. Check the relevant agreements and rights, as well as the person’s name.

Read Article 20(1)(d) in the regulation

Look beyond the direct owner

How LexaScan approaches this

Your customer may be owned by a company that is itself owned by another company. A listed person or company may be further along that chain.

  1. Listed person or company
  2. Company A
  3. Company B
  4. Your customer
Each step shows who owns the next company. Check the owners, their shares and the sanctions rules that apply.

Illustrative example. Assess the documents and applicable rules in each case.

Use company records or information from your customer to identify the owners at each level. Checking names alone does not show how those people and companies are connected.

Sources

Read the EU regulation