Beneficial ownership is a central part of preparing a foreign company for banking. A certificate of incorporation explains that a company exists. A clear ownership file explains who ultimately stands behind it. For an international investor, preparing both together helps identify missing evidence before submitting an application.
Banking and operational guide by Gustavo Scriffignano. Sources checked on 29 September 2026. Requirements depend on the jurisdiction, institution and structure; obtain advice on your specific circumstances.
What beneficial ownership means
The FATF definition looks through legal entities to the natural persons who ultimately own or control a customer. There can be several beneficial owners. Holding companies do not end the enquiry: ownership and control may operate through several layers. If ownership does not identify the relevant person, other means of control must be examined. The senior managing official fallback used in customer due diligence does not redefine that official as the true beneficial owner. Source: FATF Glossary, beneficial owner.
For your working file, distinguish the registered shareholder, the people exercising ultimate ownership or control, the directors, and the authorised signatories. One person may hold several roles. However, a signature mandate alone does not explain the ownership structure.
Beneficial ownership: why 25% is not a universal answer
As a specific UK example, Companies House identifies persons with significant control through conditions including more than 25% of shares or voting rights, the right to appoint or remove a majority of directors, and other significant influence or control. It directs companies to examine their register of members and constitutional rights. This is the UK PSC framework, not a universal banking checklist. Source: Companies House PSC guidance.
Do not simply copy a percentage from an online guide into every bank form. Ask which definition and threshold apply, how indirect holdings are treated, and which control rights need disclosure. A shareholder agreement or special appointment powers may change the analysis. Resolve uncertainty before signing a declaration.
Prepare a company banking file that can be followed
This practical preparation framework does not mean that every bank requires the same documents. Confirm the institution’s current requirements before paying for certification, translation or legalisation.
- Entity information: current registry extracts, incorporation documents, registered addresses and each entity’s business purpose.
- Ownership evidence: shareholder registers, share classes and relevant transfer records for each layer.
- Control evidence: constitutional documents and relevant agreements explaining voting, appointment and other control rights.
- A dated structure chart: legal names, jurisdictions, ownership links and references to supporting documents. Explain unresolved discrepancies openly.
- Individual verification: the identity and address evidence requested for the relevant owners, controllers, directors and signatories.
- Authority to operate: the resolutions, mandates or powers required for proposed account signatories.
Give each document a clear filename and version date. A chart showing yesterday’s shareholders alongside an older register creates an avoidable question. Similarly, inconsistent spellings of a person’s name deserve an explanation supported by identity documents.
Separate the legal baseline from the bank’s assessment
In the UK, the FCA’s financial crime guide explains customer and beneficial-owner identification, verification, understanding the ownership and control structure, and the purpose of the relationship. It also addresses enhanced checks in higher-risk cases and ongoing monitoring. Where required due diligence cannot be completed, the relationship cannot be entered into or continued. These are UK requirements and supervisory guidance, not a statement of every country’s law. Source: FCA FCG 3.2, especially 3.2.4–3.2.5.
For an account elsewhere, obtain the local legal position and the chosen bank’s application requirements separately. Request written clarification of accepted document age, certification, translations and remote identification. A professionally prepared file supports a review; it does not create a right to an account or a guaranteed opening date.
Trusts, nominees and layered structures
Trust arrangements require particular care. The FATF glossary includes settlors, trustees, protectors where present, beneficiaries or relevant classes, and other natural persons exercising ultimate effective control. Corporate parties may require further tracing. A trust should therefore not be reduced to an ordinary company share-percentage chart. Source: FATF Glossary, legal arrangements.
Where nominee arrangements exist, explain the underlying relationship accurately and obtain advice on disclosure duties. Legitimate confidentiality is compatible with proper verification. The Studio does not offer anonymous banking or structures designed to conceal ownership from an institution entitled to the information.
Ownership evidence does not replace source-of-funds evidence
Keep separate sections for the ownership explanation and the money trail. A complete chart does not explain how an initial deposit arose. Our source-of-funds guide helps organise that separate part of the application.
For example, an investor purchasing a foreign subsidiary can prepare the new chart, transfer documents and banking mandate together. The practical review should then reconcile those documents with the proposed funding transaction. This is an illustrative workflow, not a legal conclusion about who qualifies as a beneficial owner in a particular jurisdiction.
Keep beneficial ownership information current
FATF’s legal-persons guidance emphasises adequate, accurate and up-to-date information and a combination of information sources. FATF standards guide national frameworks; precise obligations arise under applicable rules. A registry record should not be treated as the only possible source of evidence. Source: FATF guidance on beneficial ownership of legal persons.
As a practical control, nominate someone to review the banking file after a share transfer, restructuring or change of control. Check the bank’s notification requirements and separate registry obligations. Store identity documents securely and use the institution’s verified submission channel.
How Studio Legale Bertaggia can assist
The value of coordinated assistance is a consistent explanation across the corporate documents, ownership chart and banking application. Subject to an agreed engagement, the Studio can help organise the file, identify inconsistencies, coordinate questions with relevant advisers and assess which issues need jurisdiction-specific legal advice.
Gustavo Scriffignano is the reference professional for banking and operational preparation. Avv. Daniele Bertaggia, founder and head of the Studio, leads legal matters; Justyna Pisyak coordinates the secretariat. The bank retains its independent decision. No account opening, timing or outcome is guaranteed.
Explore our foreign bank account assistance and international company formation services. For an initial discussion, describe the company’s jurisdictions, business activity and proposed banking needs. Ask for the appropriate secure channel before sending identity documents.