UBO data vs UBO determination
Many vendors sell “UBO data”: shareholder lists, filings, and graph edges from public sources. That is useful input. It is not Ultimate Beneficial Owner (UBO) determination under AMLR.
Transparify does not ship raw company-register extracts (as OpenCorporates- or Bundesanzeiger-style data APIs do). It returns a legally interpreted Ultimate Beneficial Owner (UBO) determination after parallel assessment of ownership interest and control via other means under AMLR Articles 51–54. That is the buying argument for Know Your Customer (KYC) / Know Your Business (KYB) platforms that will not rebuild UBO logic themselves, often stronger than for a single law-firm user.
By Noah Böker, Regulatory Strategy, Transparify
Last updated: Content is reviewed on a ~90-day cycle while AMLR implementation evolves through 2027.
What UBO data answers
Who appears on a register extract, what percentages were filed, which intermediaries exist in a corporate tree. Data APIs excel at retrieval and freshness of published facts.
What UBO determination answers
Which natural person(s) must be treated as UBO after parallel ownership-interest and control-via-other-means analysis under AMLR Articles 51–54, with documentation of grounds and open issues. Determination consumes data; it is not identical to data.
Why KYC/KYB buyers confuse the two
Procurement often starts with “give us UBO via API”. Serious compliance teams later discover they still need interpretation, special-case handling, and audit trails. Positioning Transparify against pure data providers is the point of this article and of the wider KYC/KYB cluster.
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 with national transposition obligations.
Determine the beneficial owners of one company. From €10.00 per determination, depending on your volume.
Transparify guides capture, threshold checks and documentation. You confirm the result. For several companies we prepare an individual offer on request.