UBO Screening in 2026: How to Automate and Optimise Beneficial Ownership Checks for the AMLR

The headline number (a slightly lower threshold) understates the real shift. The AMLR establishes a more detailed and harmonised framework designed to identify beneficial ownership across direct, indirect and multi-layered structures. It is not a higher bar for the same exercise; it is a different methodology.

Four structural changes drive this:

• Directive to regulation. Previous EU AML rules were directives: each member state transposed them into national law, producing divergent implementations. AMLR is a regulation. It applies directly in every EU jurisdiction from 10 July 2027, without national transposition.

• Greater EU-wide consistency. National interpretive guidance, such as BaFin’s Auslegungs- und Anwendungshinweise (AuA) in Germany, does not automatically lose all relevance. But institutions should expect AMLA Guidelines, issued by the new European Anti-Money Laundering Authority, to increasingly shape how national guidance is applied and interpreted across the EU. (AMLA, Regulation (EU) 2024/1620)

• New EU-level supervisor. AMLA, headquartered in Frankfurt, will select up to 40 high-risk cross-border financial institutions or groups in 2027 for direct supervision from 2028. Even institutions that remain under national supervision should prepare for greater EU-wide consistency in supervisory methods, data requirements and regulatory expectations.

• New UBO methodology. The three-step identification logic (ownership + control + combination) replaces the single threshold check that most processes are built around today.

AMLR Articles 52, 53, and 54 establish a more detailed identification methodology. Ownership interest and control through other means must be assessed independently and in parallel. Article 54 must also be applied where ownership and control coexist at different levels of a multi-layered ownership structure.

Step 1: The Accumulation Method

The Accumulation Method (Art. 52) requires following every ownership chain to its natural end, regardless of how small the intermediate stakes are. For each natural person discovered, the methodology is:

1. Multiply ownership percentages down each chain from the top entity to that person;

2. Add the results across all chains.

The operational implication is significant. A person holding 10% directly in Company A, plus 50% in Holding B which itself holds 40% in Company A, reaches a combined 30% (10% + 50% × 40%). Under a single-chain check, they appear twice below the threshold. Under the Accumulation Method, they are a UBO.

The threshold change compounds this. Under previous rules, “more than 25%” excluded a person holding exactly 25%. Under AMLR, “25% or more” brings that person into scope. For categories of corporate entities associated with higher money-laundering or terrorist-financing risk, the Commission may adopt delegated acts establishing a threshold below 25%. Article 52 provides that this lower threshold should generally be set at 15% or less; however, where justified by risk and proportionality, the Commission may instead set a threshold above 15%, provided it remains below 25%. The Commission must conduct the relevant assessment by 10 July 2029.

Step 2: Control Check

The Control Check (Art. 53) runs in parallel with the ownership check, not as a fallback when no ownership-based UBO is found. Control means the possibility of exercising significant influence and imposing relevant decisions; actual exercise is not required.

What qualifies as control under AMLR:

• The majority of voting rights, whether held individually or by persons acting together

• The right to appoint or remove board members

• Nominee arrangements

• Contractual control provisions

A natural person holding 15% of the ownership interest but having the right to appoint or remove a majority of the relevant board or management body may qualify as a beneficial owner through control under Article 53.

Most current compliance tools and processes run only the ownership check. A control analysis may require information beyond ownership-register data, including constitutional documents, voting arrangements, shareholder or partnership agreements, board-appointment rights, veto rights and nominee arrangements. These are rarely fully captured in public beneficial ownership registers.

Step 3: The Combination Rule

Art. 54 closes the most common structural engineering gap. It addresses multi-layered structures in which ownership interest and control coexist at different levels. Depending on the structure, beneficial owners may include natural persons who control an entity holding a direct ownership interest in the target, and natural persons who hold an ownership interest in an entity that controls the target.

Many compliance teams still treat a beneficial ownership register entry as the identification step itself. A name appears above the threshold, the process records it, and the Customer Due Diligence (CDD) file is closed. Under AMLR, that is where the problem starts.

AMLR requires the obliged entity, meaning the bank, to identify and verify beneficial owners on its own first. The register must be consulted, but it cannot be treated as the sole or automatically conclusive source for identifying and verifying beneficial ownership. Art. 24 makes the direction clear: where an obliged entity detects a reportable discrepancy, it must report it without undue delay and no later than 14 calendar days after detection. That 14-day obligation only works if the bank has already run its own analysis and found something the register does not show. A bank that treats the register as its source has nothing to compare against. It would be reporting a source back to itself.

So what does “identification” actually require? The file should contain sufficient information and supporting evidence to demonstrate how beneficial ownership was determined and verified, including relevant ownership and control analysis where applicable. A name and percentage alone may be insufficient for a complex structure.

The manual UBO process at most institutions today does not scale to the volume and complexity the three-step methodology generates. Automated UBO solutions should support ownership calculations, control analysis and Article 54 scenarios to the extent relevant to the customer structure. Human assessment may still be necessary where control depends on agreements, family relationships, nominee arrangements or other unstructured information.

Typical pain points are:

• Sequential lookups across national registers, one jurisdiction at a time

• Manual calculation of ownership percentages through multi-layer holding structures

• Separate searches for adverse media on identified persons

• No central record connecting the identification step to downstream screening and monitoring

Automated tools that rely on official registers alone will miss Art. 53 control-based UBOs. To cover the control check, platforms need to draw on additional sources such as corporate governance databases and commercial registry feeds.

Automation requirement 1: Multi-level ownership chain resolution

The system maps the full holding structure automatically, calculates Accumulation Method percentages across all chains, and surfaces every natural person at or above 25%. No manual calculation; no single-chain shortcuts.

Automation requirement 2: Control indicator detection

The system should support the collection and assessment of available control indicators, such as voting rights, appointment and removal rights, veto rights and nominee arrangements. Where these indicators are unavailable in structured form, a documented manual review may be required. Register data is necessary but not sufficient for this step.

Automation requirement 3: Reverse lookup capability

The system must support searching by person to surface their interests across corporate structures. Reverse lookup can support control analysis and broader investigations, although Article 53 does not expressly mandate this technical capability.

Automation requirement 4: Integrated downstream handoff

Every UBO identified by the system must flow automatically into PEP/sanctions screening and ongoing monitoring on the same client record. Fragmented tool landscapes (UBO identification in one system, screening in another, monitoring in a third) make it operationally very difficult to guarantee that every identified UBO completes all required checks on every update cycle.

AMLR’s broader identification net will surface more natural persons per corporate client than current practice identifies. The Accumulation Method reaches through holding structures. The Control Check adds persons who hold no ownership stake at the threshold level. The Combination Rule attributes findings from different layers to the same individual. The aggregate effect is a larger identified population per file.

Every additional identified UBO carries the same downstream requirements: identity verification, PEP and sanctions screening, adverse media screening, and integration into continuous monitoring. Institutions should ensure that identified beneficial owners are included in the required identity-verification, screening and ongoing-monitoring processes. Automated integration may reduce the risk of missed or delayed handoffs, but the AMLR does not require all controls to operate on a single platform. A corporate client that previously had one identified UBO may now have three to five. Without automation, compliance team workload grows faster than the client base.

The audit dimension goes further still. Beyond continuous monitoring, supervisors want to see the reasoning behind each risk score. The business-wide risk assessment (BWRA) methodology has to be visible and auditable in the system: a documented log of why a particular score was assigned, rather than the score on its own.

Use this checklist to see where your current process stands against AMLR’s requirements.

cleversoft’s Financial Crime Prevention platform already covers the full KYC/KYB lifecycle on a single record per client. That means PEP and sanctions screening, adverse media monitoring, transaction monitoring, a client onboarding portal, and a CRM, all in one place.

Why does that matter for UBO compliance? Every person identified as a UBO has to move into screening and monitoring without a manual handoff between systems. An integrated platform makes that automatic.

The one piece that has stayed largely manual across the industry is UBO identification itself. cleverUBO addresses it directly.

• Company or person lookup: compliance teams can look up a company and receive the full holding structure with every identified UBO, or search by person to surface corporate interests across structures.

• Native to the platform: because cleverUBO sits inside the cleversoft platform rather than beside it, every UBO it identifies flows straight into the existing screening and monitoring workflows. No manual export, no fragmentation risk, no gaps in the audit trail.

• A deeper risk picture: bringing company ownership data into screening surfaces links to PEPs or sanctioned entities inside a corporate structure earlier and with greater precision, which reduces false positives at the source.

• One consistent scoring model: the same configurable scoring logic behind cleversoft’s PEP and sanctions screening (34 configurable parameters, internally documented to reduce False Positives by 75%) also drives the risk scoring around identified UBOs.

Compliance teams keep full control of the model without needing vendor intervention. Under the AMLR’s documentation and demonstrability requirement, that control is decisive: the reasoning behind every risk score has to be documentable and defensible.

The AMLR does more than adjust the ownership threshold: it harmonises and specifies how ownership interests, control and multi-layered structures must be analysed. The three-step logic of ownership, control, and combination, combined with the Accumulation Method, surfaces more natural persons per file, requires richer data than public registers provide, and demands a documented audit trail at every step. Most institutions are still running processes built for a different regulatory world.

cleversoft’s Financial Crime Prevention platform is designed for exactly this environment. The integrated architecture combines automated UBO verification with PEP and sanctions screening, ongoing monitoring, and case management on a single client record, so nothing falls between systems and the audit trail stays intact. CleverUBO closes the remaining piece: automated ownership chain resolution and control indicator detection, feeding directly into the existing workflow.

With only around 1 in 3 EU institutions expecting to be compliant by July 2027, the preparation window is shorter than it feels. The institutions that start now build the infrastructure at the right pace. Those that wait retrofit under pressure.