UBO changes

When the ownership of an accepted client changes (shares change hands, a new investor joins, a UBO leaves), the file must be updated and the change re-assessed. The re-assessment is a review with reason UBO change: the only review besides onboarding that ends with management approval, because a change in ultimate beneficial ownership is in essence a new acceptance decision.

First, record the new structure

A review verifies information but does not change it, so record the new situation first:

• Update the organization chart in the Structure section: adjust the shareholdings, add the new shareholders or UBOs, and remove parties that left the structure. Your team can edit this directly, or the client updates it via the portal (see below).
• Every new person or company in the structure becomes a party, exactly as during onboarding: invite each new natural person to complete their own form, and collect the corporate documents for companies. This works the same as Step 3: Shareholders & other parties.

Once the new parties have handed in their part (status Pending account manager), the file is ready for review.

Checking the old situation: the structure history

Before you assess a change, you want to see what it changed from. The History button on the client’s UBO tab shows the ownership structure over time:

• The list holds Current plus one entry per completed review, dated. Every completed review archives a snapshot of the whole structure.
• Selecting a date renders the organization chart as it was then, with the differences from the previous snapshot highlighted: added parties, removed parties and changed percentages. Removed parties remain visible, so you can see exactly who left.

Use it to compare the old and the new ownership, and to document in your conclusion what actually changed. See also UBO change history.

Start the UBO change review

1. Open the client’s Reviews tab and press Start new review.

2. Choose reason UBO change.

3. Select the parties to review. At a minimum select the client company and the new and changed parties; parties whose situation is unchanged can be left out.

4. Check the previous review settings: copy the document states, partial conclusions & risk classifications, and comments from the previous review (all on by default), so the review starts pre-filled and the work concentrates on what changed.

5. Press Start new review.

The client’s status moves back to In review, and a check is created for every selected party.

One review at a time

Start new review is disabled while the client already has an open review: a client has at most one running review. Complete (or remove) the open review first.

The review runs like an onboarding review

The mechanics are identical to the onboarding review, with the same four-eyes principle:

1. The account manager verifies each check, paying particular attention to the new parties and the changed ownership percentages.
2. New persons and companies are screened once the review is with compliance.
3. Compliance verifies everything again and completes the review with a final conclusion, risk classification and decision.

Here the UBO change differs from periodic and portal-change reviews: completing the review does not finish it. The review moves to Pending approval and management takes the final decision (Is the client approved?), recording the date of the CAMS meeting, the CAMS document and any management feedback, just like at onboarding.

After the decision the client’s status becomes Accepted or Declined again, a review report (PDF) is generated, and a full snapshot of the file is archived. The UBO tab’s history then shows the old and new structure side by side as organization charts, with the differences highlighted.

When the change arrives via the portal

A party with update permission can change the structure from the portal. Such a change is automatically routed into a review with reason Portal change, and that review does not include management approval. For a change in ultimate beneficial ownership that sign-off is required, so in that case:

1. Complete the portal-change review first: verify the changed information and let compliance finish it.
2. Then start a UBO change review manually, as described above, so management formally approves the new ownership.

Only the directors changed?

A change in directors without a shift in ownership does not need management approval. Use reason Director change instead; that review completes at compliance.