What is an Ultimate Beneficial Owner (UBO)?

According to the Financial Action Task Force (FATF), an Ultimate Beneficial Owner or UBO represents the natural person or people who ultimately own or control a company and/or the natural person on whose behalf a transaction is carried out. This also includes people who ultimately exercise effective control over a legal entity or legal structure.

For more information, consult their recommendation

The UBO is the person who benefits from the company's activities and ultimately has control over its assets, operations, or decision-making processes. They are the ultimate owner or controller of a company, while a director is an individual appointed to manage and oversee the company's activities. 

Please note that there’s always a UBO for all companies. In addition, all companies registered in the European Union have a legal duty to identify their UBOs. 

As a reminder (according to the 4th AML Directive 2015/849, art. 3.6), the UBOs are:

  • The physical person who holds or controls directly or indirectly the company (the usual criteria is more than 25% of a company’s share capital or voting rights)


  • The physical person who exercises power over the management, administrative or management bodies or over the general assembly of the partners or shareholders of the legal person

In the absence of identification according to the two preceding criteria: 

  • The legal representative(s) of the legal person.



Validate a UBO’s KYC

To identify the UBO(s) you need to provide the UBO register form (each country has a register). If you are struggling to find the UBO register please provide an official document registering the firm shareholders' declaration. Then you need to send the front and back sides of each UBO identified.

Lemonway is required by law to identify the UBOs of all companies wishing to open a payment account. For listed companies, there is no need to provide the UBO registration form.

This official document must mention : 

  • Name of the registered company.
  • Legal form.
  • Company identification number.
  • Full address of the company.
  • The title, names, usual names, pseudonyms, first names, date and place of birth, nationality, and personal address of all beneficial owners.
  • The role of each beneficiary,
  • The date on which the persons became beneficial owners of the company.

💡 Please send the front and back sides of the UBOs’ ID card or passport and a copy of the UBO official register.

Please find below the type of document required per country : 


Country Document name Useful Link 
🇫🇷  France Extrait du registre des Bénéficaires effectifs ("DBE S-1") 👉 https://www.infogreffe.fr/

🇮🇹  Italy 

Visura Camerale ("menzionando i beneficiari")

👉 Included in the Italian commercial register 

🇪🇸  Spain

Modelo 200 ("Form 200") or Acta de titularidad real ("documentos expedidos por los Notarios")

👉 https://sede.registradores.org/site/

🇩🇪  Germany

List der gesellshafter  

🇵🇹  Portugal

Extracto do Registo Central do Beneficiario Efetivo (RCBE)  👉  https://rcbe.justica.gov.pt/

🇬🇧  United Kingdom

CS01 form (mentioning the UBOs of the company) 👉 https://beta.companieshouse.gov.uk/ .

🇦🇹  Austria

Extract from the UBO Register 👉 https://www.wiereg.at/en/

🇳🇱  Netherland

Extract from KVK uittreksel UBO-register 👉 https://www.kvk.nl/bestellen/#/

🇵🇱  Poland

CEIDG-1 form mentioning the UBOs of the company 👉 https://ekrs.ms.gov.pl/web/wyszukiwarka-krs/strona-glowna/

🇧🇪  Belgium

Extrait du Registre des bénéficiaires effectifs 👉  https://eservices.minfin.fgov.be/myminfin-web/

🇨🇭  Switzerland

UBO Extract (where you need to choose the right cantonal registry of commerce) 👉 https://www.zefix.ch/en/hra 

🇬🇷  Greece

Extract from the Central UBO Register established in the General Secretary of Information Systems of the Ministry of Finance 👉 https://www.gsis.gr/polites-epiheiriseis/epiheiriseis/mitroo-pragmatikon-dikaioyhon

🇱🇹  Lituania

UBO Extract from the registrucentras.lt 👉 https://www.registrucentras.lt/jar/p_en/

🇪🇪  Estonia

Kehtivad tegelikud kasusaajad / UBO of the company 👉 https://www.rik.ee/en/e-business-register



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