Frequently asked questions

AMLR (EU) 2024/1624 creates a directly applicable European framework for anti-money-laundering rules, including harmonised expectations around Ultimate Beneficial Ownership determination, central registers, and supervisory cooperation. National laws remain relevant for implementation details and local procedures, but core concepts (parallel assessment of ownership interest and control, register access rules, and risk-based supervision) are increasingly aligned at EU level rather than fragmented across member states.

AMLR is a Regulation: large parts apply directly across the EU once in force. AMLD6 is a Directive: member states must transpose certain provisions into national law, including rules on access to beneficial ownership information and related procedural frameworks. In practice, obliged entities and professional advisors need to follow the combined effect of both instruments plus national implementing legislation: AMLR for the harmonised baseline, AMLD6 and national law for transposition and enforcement on the ground.

AMLR enters into application on a phased EU timeline (with key dates from 2027 onward depending on the provision). During the transition, many organisations still operate under existing national AML and register rules while preparing for AMLR-aligned processes. Transparify is designed around the AMLR assessment logic so teams can adopt structured UBO workflows before, during, and after national transposition, but you should always verify current deadlines and obligations with qualified counsel for your jurisdiction.

AMLD6 strengthens transparency around who can access beneficial ownership information and under which conditions entities must ensure accurate register data. Legal entities and certain other arrangements within scope of national transposition must identify their Ultimate Beneficial Owners and ensure timely updates. The exact obliged-party list and filing mechanics depend on member-state implementation. Transparify supports the assessment and documentation side of that workflow; it does not replace your obligation to file through the official channel where registration is required.

Under the AMLR framework, an Ultimate Beneficial Owner is a natural person who ultimately owns or controls a legal entity or arrangement, through ownership interest, control factors, or both, assessed in parallel per AMLR Art. 51. Older national practice often emphasised capital thresholds alone. AMLR expects ownership interest (Art. 52) and control (Art. 53) to be evaluated together, including cases where control exists without a large direct stake. Transparify structures assessments along these pillars rather than treating a single shareholding figure as the full answer.

Transparify does not wait until ownership is “finished” before looking at control. For each entity in scope, the tool captures ownership interests (shares, voting rights, profit rights, liquidation balance where relevant) and control factors (appointment rights, vetoes, agreements, acting in concert, nominee structures, and more) as separate analytical tracks, consistent with AMLR Art. 51. Either track can surface a Ultimate Beneficial Owner candidate; results are documented with the reasoning visible for professional review.

That is a core AMLR scenario. A person may cross the ownership-interest threshold without exercising control, while another exercises control through veto rights, agreements, or informal influence without a large stake. Transparify records both dimensions independently and flags where different natural persons emerge from each track, so your team can confirm, reconcile, or document why multiple UBOs are reported, rather than collapsing everything into a single shareholding view.

Pooling agreements and coordinated voting are captured as structured control inputs (acting in concert, aligned voting blocks, and contractual arrangements) rather than ignored because no single holder exceeds a capital threshold alone. Veto rights and similar special rights are documented as qualitative control factors with their scope and target entity specified. The assessment engine applies threshold and qualitative rules per entity layer; your team confirms the legal characterisation before export.

A nominee arrangement exists where a person holds an interest on behalf of another who retains economic benefit or control. Transparify includes a dedicated nominee workflow: you record the nominee, the nominator, and the attributed interest, and the tool routes control attribution accordingly. Assessment is guided: the system surfaces the structure and asks for confirmation; it does not autonomously conclude legal nominee status without your input.

You model each legal entity layer with its direct holders and percentages. Transparify walks the structure recursively: where a corporate holder exceeds the relevant threshold at a layer, you continue into that entity’s own ownership and control data. Threshold logic is applied at each level with direct interests at that level, not by multiplying quotas along the chain as a shortcut. This matches the professional AMLR workflow for nested holdings, Kommanditgesellschaften, and intermediate HoldCos.

Register and commercial-data APIs typically return static share lists or capital figures. Transparify is a workflow and assessment platform: it combines ownership interests, all relevant control mechanisms, nominee and trust overlays, Senior Management Official fallback, and audit-ready documentation. It suggests structure and asks targeted questions; your team confirms outcomes. It is not a substitute for a register API, and it does not issue autonomous legal conclusions.

Both, but the product is optimised for professional AML and corporate governance workflows. Law firms, tax advisors, corporate service providers, and in-house compliance teams use Transparify to run repeatable, documented UBO assessments across client entities. Companies can use it directly for internal documentation and disclosure preparation, especially where no external advisor is involved.

Advisors handle recurring assessments with similar methodology but different structures each time. Transparify standardises the six-step assessment path, preserves drafts, exports PDF and XML reports, and leaves a traceable record of what was entered and concluded. That reduces rework, supports file consistency across mandates, and gives partners a reviewable basis without replacing their professional judgment.

Companies can use Transparify to prepare and document their UBO assessment internally. Transparify does not submit filings to national registers on your behalf. Where AMLD6 and national law require registration or update through an official portal, your organisation or advisor remains responsible for transmission and legal accuracy of the filed data.

Transparify supports common German and European private-law forms used in professional practice, including GmbH, UG, AG, KG, GmbH & Co. KG, OHG, and nested combinations with holding structures. Legal-form-specific assessment rules (capital vs. voting labels, general partner logic, cooperative specifics where implemented) are applied automatically when you select the entity type. If you have an unusual form or cross-border hybrid, contact us to confirm coverage.

The guided workflow has six steps: Entity Information, Ownership Structure, Control Factors, UBO Determination with Senior Management Official fallback, Beneficial Owner Information, and Structured Output. You can prefill entity data from the commercial register where available, enter or confirm ownership percentages and control rights, resolve edge cases through structured prompts, and export documented results. Progress saves as drafts so you can pause and resume.

Useful sources include commercial register excerpts, shareholder lists, articles of association, partnership agreements, voting or pool arrangements, organograms for group structures, and any known nominee or trust documentation. For nested entities, gather the same materials for relevant subsidiaries and holding companies. The more complete your starting documents, the less manual entry is required, though Transparify always allows you to enter data manually and mark items for verification.

Transparify does not provide legal advice, does not file register entries automatically, and does not make binding autonomous UBO determinations. It does not replace customer due diligence beyond the ownership and control assessment scope, and it is not a global KYC or banking onboarding platform. Sanctions screening, transaction monitoring, and country-specific filing interfaces remain outside the product unless explicitly added in a future release.

No. Transparify produces structured assessment documentation (PDF and XML) that you can use when preparing a filing or internal compliance record. Submission to any national beneficial ownership register or supervisory body remains your responsibility or that of your appointed advisor.

No. Transparify is assessment-support software. It structures inputs, applies the configured AMLR-oriented methodology, and documents outcomes. Legal interpretation of agreements, cross-border questions, and final responsibility for regulatory compliance remain with qualified professionals and the obliged entity.

The user organisation and the professionals who review and sign off on the assessment remain responsible. Transparify highlights inferred values, register-sourced prefills, and areas that need confirmation, but it does not warrant that a given structure is legally complete without your validation.

Data is processed for the purpose of running your assessments, hosted in European data centres, and stored encrypted. You can delete data from your account in line with our privacy policy. For full details see our Privacy Policy and Security page.

EU and national regulators set obligations on obliged entities, not on a single certified software standard for UBO tools. AMLR and AMLD6 define what must be achieved in transparency and assessment; tools vary in how they support that work. Transparify is built as a professional workflow and documentation platform aligned with AMLR Arts. 51 to 54, not as an officially accredited filing gateway. Evaluate any tool against your firm’s compliance policies and applicable law.