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Back to What is an Ultimate Beneficial Owner (UBO)? A Comprehensive AML/KYC Guide

What happens if a company does not have anyone who owns 25% or more?

AML Learnings · Article FAQ

Detailed Explanation

If no individual meets the ownership threshold (e.g., if a company has 10 unrelated shareholders each owning 10%), the institution must apply the **Control Test**. If no individual exercises effective operational control through other channels, the institution identifies the company’s **Senior Managing Official (SMO)**—typically the Chief Executive Officer or Managing Director.

Disclaimer: This material is for educational purposes only. Every financial situation is unique. Consult with a certified professional before making significant decisions.