Beneficial ownership verification for complex corporate structures

We're onboarding a client with a multi-layered corporate structure spanning 4 jurisdictions (BVI, Luxembourg, Singapore, UK). Identifying the UBOs is proving extremely difficult — each layer adds opacity.

How do you approach beneficial ownership verification when the structure has more than 3-4 layers? At what point do you decline the relationship due to insufficient transparency? What tools or databases do you find most useful for corporate unravelling?

This is one of the most challenging aspects of KYC. Our approach:

1. Start with publicly available registries — UK's PSC register, Luxembourg's RBE, Singapore's ACRA. BVI is obviously the hardest.
2. Request the full ownership chart from the client with certified documents at each layer. If they can't or won't provide it, that's a red flag.
3. Use commercial databases — we find Moody's Orbis and Refinitiv World-Check useful for cross-referencing.
4. Apply the 25% threshold at each layer to identify anyone with indirect control.

For BVI entities specifically, we require certified copies of the Register of Members and Register of Directors directly from the registered agent.

One additional challenge with complex corporate structures: multi-jurisdictional ownership chains where each country has different disclosure requirements. We had a client with a holding company in Luxembourg, operating entities in Dubai and Singapore, and ultimate beneficial owners who were nationals of a fourth country.

Our approach: we created a tiered verification process. For the direct legal entity, we require certified registry documents. For each layer above, we require organizational charts supported by official filings where available. For the ultimate beneficial owners, we require ID verification plus source-of-wealth documentation.

The Corporate Transparency Act has helped for US entities but international chains are still a manual process. We've found that being upfront with clients about what we need — and why — dramatically reduces the back-and-forth. Most clients aren't hiding anything; they just don't understand what compliance requires from them.

Also worth noting: the 25% ownership threshold isn't the only trigger. Control through voting rights, board appointments, or contractual arrangements can also make someone a beneficial owner even with less than 25% equity.