Knowing who ultimately owns or controls a company — the ultimate beneficial owner, or UBO — is the heart of corporate due diligence. But there is a trap many firms fall into: treating a glance at the PSC register as the whole job. Identifying a UBO and verifying it are different tasks, and the Money Laundering Regulations are explicit that the register alone is not enough. Proper UBO verification is where serious KYB is won or lost.
Identify vs verify: the crucial distinction
| Identify | Verify | |
|---|---|---|
| Question | Who is the beneficial owner? | Can I prove it independently? |
| Source | PSC register, customer-provided info | Independent evidence, corroboration |
| Risk if skipped | You don't know who you're dealing with | You took a claim on trust |
Identifying tells you the name; verifying tells you it is true. Criminals rely on firms stopping at the first step.
The PSC-register trap
This is the single most common UBO mistake: pulling the PSC register, seeing a name, and treating the job as done. The register is the beginning of the enquiry, not the end of it.
The layered-ownership challenge
UBO verification gets hard when ownership runs through chains of companies and trusts.
You're verifying the UBO of Target Ltd. The PSC register names a corporate owner. Work it.
Target Ltd's PSC register lists 'Holdco Ltd' as the only PSC. Do you record Holdco as the UBO?
How ECCTA changes (but doesn't replace) this
The Companies House identity-verification reform under ECCTA makes the PSC register more reliable by verifying the identities behind it. That is genuinely helpful — but it raises the baseline rather than removing your duty. You still verify the UBO yourself; the register is simply a stronger input than it was.
What good UBO verification involves
- Identify candidatesUse the PSC register and customer information to find likely UBOs.
- Trace the chainFollow corporate and trust ownership up to real individuals.
- Apply all control testsConsider shares, voting, board control and significant influence — not just 25%.
- CorroborateConfirm with independent evidence, not the customer's word alone.
- Screen the UBORun the verified individual against sanctions, PEP and adverse media.
- Document and refreshRecord the basis, and re-verify as ownership changes.
Where Probitas fits
UBO verification is exactly the work a Probitas company profile supports: it reads the public record, surfaces ownership and control signals, helps trace layered structures, and screens the individuals it identifies against sanctions, PEP and adverse media sources — everything anchored to its origin so you can verify, not just identify. The corroboration and final judgement remain yours.
UBO
What is a UBO?
The ultimate beneficial owner — the real person who ultimately owns or controls a company, even through layers of other companies, nominees or trusts. Identifying and verifying the UBO is central to corporate due diligence.
Can I rely on the PSC register to verify a UBO?
No. The Money Laundering Regulations are explicit that you do not satisfy your due-diligence duties by relying only on the PSC register. It is a starting input — historically self-declared and sometimes inaccurate — not a substitute for independent verification.
What is the difference between identifying and verifying a UBO?
Identifying establishes who the beneficial owner is; verifying confirms it with independent evidence. Criminals rely on firms stopping at identification and taking ownership claims on trust.
How do you verify a UBO behind layered ownership?
Trace the ownership chain through corporate owners and trusts up to real individuals, apply all the control tests (shares, voting rights, board control, significant influence), corroborate with independent evidence, and then screen the verified person for risk.
Does Companies House reform change UBO verification?
The identity-verification regime under ECCTA makes the PSC register more reliable, which helps. But it raises the baseline rather than removing your duty — you still verify the UBO yourself, with the register as a stronger input.
Sources
This guide is written from primary sources. Each is linked below; claims in the text link to the specific reference they rely on.