For a bank's or payment provider's compliance team the main KYB question is simple: who ultimately owns and controls the company. If holdings in several countries, a trust or a foundation sit between the applicant and the person, the answer gets complicated — and the risk of rejection grows. The good news: a complex structure is not a problem in itself if its logic is clear and documented. It is the heart of our KYB/KYC support.
In short: draw the chart down to the natural persons, attach documents for every layer and briefly explain why the structure is set up this way. Opacity worries providers more than complexity.
Who counts as a UBO
A UBO (ultimate beneficial owner) is a natural person who directly or indirectly owns a significant share of the company or controls it in another way. In the EU the typical threshold is more than 25% of shares or votes, but many banks and providers apply a lower one, such as 10%. If nobody is above the threshold, the person exercising control — for example a senior manager — is disclosed.
What to prepare for each layer
| Layer | Documents |
|---|---|
| Applicant company | Constitutional documents, registry extract, register of shareholders and directors |
| Intermediate companies | The same documents for each, current and apostilled where required |
| Trust or foundation | Trust deed or charter; settlor, trustee, beneficiaries and protector details |
| Natural persons | Passport, proof of address, source of funds, sometimes a CV |
How to explain the structure's logic
- Draw the chart. All layers, percentage holdings, countries of incorporation, directors' roles.
- Describe the purpose of each layer. A holding for several operating companies, an investment structure, succession planning.
- Show substance. Where activity happens, where staff sit, who makes decisions.
- Remove what is not needed. Layers with no function are best simplified before applying — they raise questions without adding value.
- Synchronise data. Shares and names in the chart, registers and forms must match.
What makes providers nervous
- Nominee directors or shareholders with no disclosure of the real owner.
- Companies in jurisdictions without public registers and no explanation why.
- Frequent recent changes of ownership.
- Holdings split just below the disclosure threshold with no business rationale.
Frequently asked questions
Do minority shareholders need to be disclosed?
Everyone above the provider's threshold must be. Many ask for the full shareholder register, so hiding minority holders makes no sense.
Can I pass KYB with a trust in the structure?
Yes, if every role in the trust is disclosed and its purpose is clear. Providers serving private wealth see such structures regularly.
What if the structure has already scared a bank off?
Find which layer raises questions and decide whether to explain it better or simplify it. Sometimes it is more effective to open the account for an operating company with transparent ownership. Corporate documents for restructuring help too.
Is a complex structure blocking an account or payments? Send a request on the KYB/KYC support page and we will draw the chart, collect documents for every layer and prepare the explanation for the provider. Then we help with opening a business account.