Control via other means under AMLR
Control via other means is the qualitative counterpart to ownership-interest tests in Ultimate Beneficial Owner (UBO) determination. Under AMLR, firms that only chase percentages will miss UBOs who influence through rights, arrangements, or roles.
By Noah Böker — Regulatory Strategy, Transparify
Last updated: Content is reviewed on a ~90-day cycle while AMLR implementation evolves through 2027.
Typical indicators (non-exhaustive)
Appointment/removal rights for management bodies, veto rights over reserved matters, dominant influence via agreements, and certain trust/foundation roles. Always map to the regulation’s wording and case facts.
- Cite the instrument clause or factual arrangement
- Name the natural person and the entity controlled
- Separate this finding from any ownership percentage narrative
Software support without overclaiming
Good tooling highlights candidate clauses and asks structured questions. It should not emit unreviewed legal conclusions labelled as “verified UBO”.
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.