Ownership interest vs control via other means

Ownership interest analysis looks at rights that are typically expressed as percentages or comparable economic stakes — for example capital participation and voting rights, depending on the entity type and the legal test applied. Under AMLR, firms should capture the rights that matter for the entity form rather than forcing every structure into a GmbH-like share model.

Document the source of each figure (shareholder list, articles, register extract) and whether rights diverge (e.g. capital vs voting).

Control via other means covers influence that is not adequately described by ownership percentages alone: appointment and removal rights, veto rights, trust/foundation roles, concerted action, and similar arrangements. A person may be a UBO on this ground even when below a headline ownership threshold.

The documentation burden is higher: cite the clause, role, or factual arrangement, and record why it amounts to control for UBO determination purposes.

State which ground(s) apply, for which natural person, and with which evidence. Do not imply that a screening vendor “identified” the UBO if what you actually performed was a structured determination with professional judgement.