International UBO: How Different Countries Approach Ultimate Beneficial Ownership

Many countries now have legislation around the recording of UBO data, but there is no international standard to what information is required and how compliance to these laws are enforced.

Money laundering is not just a problem in the UK, it affects every country on the planet. With up to USD$3 trillion in dirty funds being cleaned through the global economy each year, causing many times this figure in economic damage, very few governments can afford to be complacent on this type of financial crime.

As such, most governments have introduced and continue to strengthen anti-money laundering legislation. These aim to protect each individual economy from economic damage but to also comply to international standards, especially in the case of developing economies, to avoid being labelled a high risk country for the facilitating of money laundering schemes which ultimately target the most developed economies.

Ultimate beneficial ownership is a key part of most countries AML regulations but most follow no standardized approach and there are differences in the information required.

So lets take a look at how different countries approach ultimate beneficial ownership or see what UK UBO law entails.

USA

The world’s largest economy and the most affected by money laundering, the USA introduced the Corporate Transparency Act on 1st January 2021 which laid out the requirement for reporting UBOs of over 25% or more.

From the start of 2025, business entities will be required to report all UBOs above this threshold to the US Department of the Treasury Financial Crimes Enforcement Network. This data will be kept in a non-public register, and data will only be released upon the request of a federal agency.

European Union

The EU lays out the AML requirements of member states via their Anti-Money Laundering Directives. The 4th Anti-Money Laundering Directive introduced the requirement to keep a register of UBOs, which was the strengthened by the 5th Money Laundering Directive. These directives also set the UBO reporting threshold to 25%.

However, it is up to each individual nation to decide how they implement this into their legislation and so there is no standardized approach and its major economies bear looking at.

France

France’s UBO register is attached to its Trade and Companies Register, which is maintained by the commercial courts. Non-confidential information is available to the public.

Germany

In Germany, UBO data is kept in the Transparency Register which is maintained by the Bundesverwaltungsamt. This is accessible to those who have a ‘legitimate interest’ in the data contained within; such as law enforcement agencies, regulators, and those obligated to record UBO data on clients and business partners.

This means that those companies outside of German AML law are not classed as having a legitimate interest and are not able to access the register.

Spain

Any company with a registered address or who carry out their main activity in Spain need to submit their UBO to the Spanish Central UBO Registry. Access to this register is limited to those with ‘legitimate interest’ and anyone wishing to access it must prove their identity.

Ireland

Ireland maintains the Central Register of Beneficial Ownership of Companies and Industrial and Provident Societies. This is a non-public register and only available to those with a ‘legitimate interest’.

Hong Kong

Hong Kong does not have a central UBO register, instead each company is required to maintain a list of all its significant controllers. This is an individual with 25% or more ownership, voting rights, or control of a company.

These list must be kept at the registered office of a company, or a location otherwise agreed upon by regulators, and made available upon demand to authorities or other significant controllers. There is no public access.

India

India has recently reduced its UBO reporting threshold to 10% upon the order of its Ministry of Finance. Currently, India has no central UBO register but all companies are required to maintain a list of all its UBOs, to be made available on request by authorities, company members and those obligated to confirm ownership.

Under Indian AML law, reporting entities (e.g. financial institutions) must confirm the UBO of a company at the onset of a business relationship with a client.

Singapore

Singapore the Accounting and Corporate Regulatory Authority maintains a register of UBOs. This is not publicly available and can only be accessed by law enforcement agencies and relevant regulatory bodies.

It is now common for corporate structures span international jurisdictions, especially those created to facilitate financial crimes, and companies need to have the tools in place to identify exactly who they are dealing with, both to protect themselves and meet legal requirements.

We offer the most complete UBO data available, listing ownership from as little as 0.1%, so you can spot any bad actors trying to hide below the reporting thresholds and have a strategic advantage for identifying UBOs. 

We also have revolutionized how beneficial ownership structures are presented, making them quick and easy to understand so your investigations will be faster and more accurate.

Speak to an expert today to see for yourself how we will allow you to do smarter, safer, and faster business.