CONCEPT
Ultimate Beneficial Owner (UBO) threshold?
What's on this page?The full concept entry as stored in Postgres. Definition, regulatory origin, risk consequence, and any per-jurisdiction overrides and role guidance authored for it. Sources at the bottom are the only citations the AI Generator is allowed to use when producing content about this field.
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What's on this page?The full concept entry as stored in Postgres. Definition, regulatory origin, risk consequence, and any per-jurisdiction overrides and role guidance authored for it. Sources at the bottom are the only citations the AI Generator is allowed to use when producing content about this field.
ubo-threshold · domain compliance-aml-kyc · v1
risk · highpublished
Definition
The percentage of ownership or control above which a natural person is treated as a beneficial owner of a legal entity. EU directives use 25% as the indicative threshold; lower thresholds apply for high-risk customers.
Risk consequence
Failure to identify a UBO at the correct threshold can constitute non-compliance with AML obligations and may trigger a regulator-reportable breach. In Luxembourg, the CSSF can impose administrative sanctions up to EUR 5 million or 10% of annual turnover.
Jurisdiction variants
| Jurisdiction | Override | Note |
|---|---|---|
| LU | Under the Luxembourg law of 13 January 2019 implementing AMLD5, the UBO threshold is 25%. Lower thresholds apply for high-risk customers; CSSF guidance recommends 10% for politically exposed persons (PEPs). Origin override: Loi du 13 janvier 2019 instituant un Registre des bénéficiaires effectifs | RBE (Registre des bénéficiaires effectifs) registration is mandatory within 30 days of incorporation. |
| EU | — uses base definition | — |
Role guidance
| Role | Guidance | Permission note |
|---|---|---|
| kyc-analyst | Confirm UBO identity via passport or national ID. If ownership is 25–50%, also verify by source-of-funds statement. Above 50%, escalate to enhanced due diligence regardless of risk score. | You can flag a UBO as 'pending verification' but cannot mark it 'verified' without manager approval. |
| compliance-officer | Approve or reject the analyst's UBO determination. For PEPs or sanctioned jurisdictions, EDD is mandatory regardless of ownership percentage. Document the rationale in the case file. | — |
Workflow hints
| App / module | Current step | Next step | Blockers / deadline |
|---|---|---|---|
elyxen kyc / onboarding | UBO identification | Source of funds verification | — |
Sources
AMLD5 Art. 30 Directive (EU) 2018/843 — 5th Anti-Money Laundering Directive, Article 30 (Beneficial Ownership Information) https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX%3A32018L0843 | EU | v2018 |
FATF R.10 FATF Recommendation 10 — Customer Due Diligence https://www.fatf-gafi.org/en/publications/Fatfrecommendations/Fatf-recommendations.html | global | v2023-update |
CSSF 12/552 CSSF Circular 12/552 on central administration, internal governance and risk management https://www.cssf.lu/en/Document/circular-cssf-12-552/ | LU | v2020-revision |
Audit
Status
published
Version
1
Reviewed by
DEMO-ONLY (sample content, awaiting domain expert per KE-Q3)
Last reviewed
5/12/2026