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
- The Buyer Readiness Passport, graded A to D
A buyer's identity and funding evidence, graded A to D, deciding whether they may be put in front of a seller at all. Grade C is the trap: we know exactly…