Five Roles
CEO, Representative, Shareholder, UBO, and ABO. Every stakeholder on a case is one of these.
Equal Check Coverage
All five roles support the same AML screening and identity verification. Role does not mean tier.
Corporate Model
Ownership resolves down a shareholding chain to natural persons. Structures that don’t fit are modelled with ABO.
The Five Roles
Shareholder, UBO, and ABO each have to be switched on individually under Shareholder Types in the Ownership Structure step. A role that isn’t enabled cannot be added by the client, and rules that target it will never fire.
How the Ownership Model Resolves
The Ownership Structure step is built around a corporate ownership model. It expects the ownership of the applicant company to resolve, layer by layer, until it reaches natural persons (or a government entity). Three settings control how far that goes:
When Full ownership list is active, the form is validated on submission against two conditions:
- The case contains at least one beneficiary of any kind.
- Every company beneficiary of type Shareholder, UBO, or ABO has at least one individual beneficiary behind it.
What ABO Is For
The corporate model works cleanly for companies whose ownership is a chain of percentage stakes. It does not describe every legal entity. Common examples: general partnerships, foundations and associations with no members, co-operatives, and companies so widely held that nobody crosses the ownership threshold. ABO exists for exactly these cases. It captures a person who is genuinely a beneficial owner in substance, without asserting a shareholding percentage that doesn’t exist. Because an individual ABO satisfies the beneficiary requirement on its own, it also resolves the structure without forcing you to invent an ownership layer.The API also exposes a free-text
positions list on each beneficiary (up to three entries, 50 characters each). Use it to record the real-world title — Partner, Trustee, Founder, Managing Member — next to the platform role, so a reviewer can see what the person actually is. See Collect Information.Mapping Real Structures Onto the Roles
Worked Examples
A UK private limited company with two individual owners
A UK private limited company with two individual owners
Structure: Registered LTD. Two directors, who are also the only two shareholders, holding 60% and 40%.How to model it:
- Both individuals added twice — once as CEO in the Director Information step, once as Shareholder in the Ownership Structure step. The same person legitimately holds more than one role.
- Ownership percentages recorded as 60% and 40%.
- If your threshold is 25%, both must be declared.
- Because both shareholders are natural persons, the chain terminates and the structure validates.
An operating company owned through a holding company
An operating company owned through a holding company
Structure: Applicant is an operating company, 100% owned by a holding company, which is in turn owned by two individuals at 50% each.How to model it:
- The holding company added as a company Shareholder of the applicant, at 100%.
- The two individuals added as individual UBOs behind the holding company, at 50% each.
- With Full ownership list enabled, the holding company must have at least one individual beneficiary attached to it. Adding only the holding company and stopping there triggers the incomplete ownership structure error.
A general partnership registered under one partner's name
A general partnership registered under one partner's name
Structure: A foreign law firm registered in Hong Kong. Legally a general partnership with several partners, but Hong Kong’s foreign law firm registration rules require a single named individual on the certificate, so the Business Registration Certificate names one partner and shows legal status as “Individual”. There is no shareholding and no percentage split between the partners.This is the case the platform’s corporate model handles least naturally, and the one most likely to be mis-routed. Two things frequently go wrong: it gets treated as a sole proprietorship because of the certificate, or it gets forced into shareholder fields and fails validation.How to model it:
- Run it as a KYB case, not an individual KYC. The certificate showing “Individual” reflects a registration rule, not the entity’s actual legal form. A multi-partner firm is a business entity.
- Do not use the Sole Proprietorship step. That step hides the director and shareholder sections and is built for a genuine single owner — it would misrepresent the firm and lose the other partners entirely.
- Add every partner as an individual ABO, including the one named on the certificate. Partners are beneficial owners in substance without holding percentage stakes, which is precisely what ABO is for. Set Disclose Percentage to Off or Optional so no stake has to be asserted.
- Record the real title using the
positionsfield (Partner) so reviewers see the actual relationship. - Handle the certificate mismatch as documentation, not structure. Capture the named individual exactly as they appear on the Business Registration Certificate, and evidence the remaining partners with a supporting document — a partnership agreement or a signed declaration of the partners — via Document Management. The platform record then stays consistent with the certificate while still reflecting the true multi-partner reality.
A company where no owner meets the ownership threshold
A company where no owner meets the ownership threshold
Structure: Ownership is dispersed and no single holder reaches your Shareholder Threshold.How to model it:
- Declare any shareholders that do cross the threshold as normal.
- Add the senior managing official as an individual ABO so the case still has a screened natural person attached, rather than resolving to nobody.
- Note the reason in the case — a questionnaire answer or an uploaded declaration — so the absence of a UBO is an evidenced decision rather than a gap.