beneficial owner

Whoever ultimately owns or controls an entity, identified from 25% ownership or voting rights upward.

A company selling a property is not a person, and identifying the director who signed is not identifying the customer. The obligation runs to whoever is behind the entity.

Twenty-five per cent is the threshold in the Regulations. Where no individual meets it, the senior managing official is identified instead — a fallback, not an equivalent, and it should be recorded as the fallback it is.

Where this comes up

Related definitions