Accumulation method under AMLR
The accumulation method addresses how ownership interests held through different channels or persons may need to be combined for Ultimate Beneficial Owner (UBO) determination. It is a legal-analytical concept — not a licence to multiply every percentage in a holding chart.
By Noah Böker — Regulatory Strategy, Transparify
Last updated: Content is reviewed on a ~90-day cycle while AMLR implementation evolves through 2027.
What accumulation is trying to prevent
Without accumulation logic, structures could be engineered to keep each visible stake below a threshold while the same natural person effectively commands a larger combined interest. AMLR-era practice expects firms to look through coordinated holdings with documented reasoning.
Worked sketch (indicative)
Always validate against the operative AMLR wording and national guidance for the case.
Relation to multi-layer graphs
See also multi-layer ownership structures and the combination-rule glossary entry. Transparify’s calculation philosophy emphasises per-layer thresholds and explicit control findings rather than opaque chain products.
Related reading
Primary sources
- Regulation (EU) 2024/1624 (AMLR)Anti-Money Laundering Regulation — directly applicable from 10 July 2027.
- Directive (EU) 2024/1640 (AMLD6)Sixth Anti-Money Laundering Directive — national transposition obligations.
- Regulation (EU) 2024/1620 (AMLA founding regulation)Establishes the Authority for Anti-Money Laundering and Countering the Financing of Terrorism (AMLA).
Run a structured UBO determination workflow
Transparify guides capture, threshold checks, and documentation — your firm confirms decisions.