Lesson 24 of 28
Indirect ownership and the ownership chain
What you will be able to do
This lesson is for the compliance officer. Owners do not always hold their shares in their own name. You will record that one owner now holds her shares through a holding company, read the Ownership Chain view, which shows how many levels lie between the owners and the company, and record ownership links for the group view, called Effective Group Ownership.
Before you start
- The three owners are on the register.
- You are signed in as the compliance officer, with permission to edit UBO records.
- You know the structure from the shareholding documents. The holding company in this example is invented.
Steps
- 1
Open Ownership Chain
In the UBO Register, select Ownership Chain on the left. The line at the top gives the total ownership, the maximum chain depth, the typical depth and the number of indirect owners. All three people are direct, so the depth is 1 level and there are no indirect owners.
- Select Ownership Chain
- 2
Go back to the register and edit an owner
One shareholder has moved her shares into a holding company. Select Register on the left, then Edit on the row of Huda Ibrahim Al Marri.
- Select Register3
- Select Edit
- 3
Choose Indirect and name the company in between
Open Ownership Type and choose Indirect. In Intermediate Entities type the company that now holds the shares, Al Marri Family Holding LLC. If there were several companies in a row, you would list them in order, separated by the greater than sign. The grey example in the box shows how.
- Select Ownership Type
- Choose Indirect
- Type e.g. Holding Company A > Sub-Holding B:
Al Marri Family Holding LLC
- 4
Select Save Changes
Select Save Changes. A message says UBO record updated. Her percentage has not changed, only the way it is held.
- Select Save Changes
- 5
Read the chain again
Select Ownership Chain. The top line now shows a maximum chain depth of 2 levels and 1 indirect owner, and her line in the table shows the ownership type Indirect. The person who controls by appointment is listed too, at 0 percent.
- Select Ownership Chain3

- 6
Find Effective Group Ownership
Scroll down to Effective Group Ownership. This view is for groups of companies: it traces ownership up through companies that own other companies, multiplies the percentages along each path, and marks anyone who ends up with 25 percent or more as a beneficial owner. It works from ownership links, called edges, and none are recorded yet.
- 7
Look at the owner type
Open Owner type. Person is a real person who owns part of this entity. Entity is another company registered in your organisation that owns part of this one; choosing it lets you pick that company from a list. Choose Person.
- Select Owner type
- Choose Person
- 8
Add the first ownership link
In Owner type the first shareholder's name, Obaid Saif Al Hammadi. In percent of this entity type 50, add a note, and select Add Edge. A message says Ownership edge added, and he is listed above with 50.00% and the tag UBO.
- Type Full Name:
Obaid Saif Al Hammadi - Type % of this entity:
50 - Type e.g. via nominee agreement:
Direct shareholding - Select Add Edge
- Type Full Name:
- 9
Add the second ownership link
Add the other shareholder the same way: Huda Ibrahim Al Marri, 50 percent, with a note that the shares are held through the holding company. Both now appear with 50.00% and the tag UBO. Links cannot be edited or removed on this screen, so check each one before you select Add Edge.
- Type Full Name:
Huda Ibrahim Al Marri - Type % of this entity:
50 - Type e.g. via nominee agreement:
Held through Al Marri Family Holding LLC - Select Add Edge
- Type Full Name:
How to check it worked
Ownership Chain shows a maximum chain depth of 2 levels and 1 indirect owner, and Effective Group Ownership lists the two shareholders at 50.00% each with the UBO tag.
Common mistakes
- Adding the holding company to UBO Records. The register lists people. Record the person, choose Indirect, and name the company in Intermediate Entities.
- Forgetting that changing how shares are held is a register change. It appears in the change log and must be filed.
- Typing ownership links that do not add up. The group view multiplies percentages down each path, so a wrong link gives a wrong owner.
Check your understanding
1. An owner holds 50 percent of your company through her own holding company. How is she recorded?
- A.The holding company is added as the owner
- B.She is the owner, with Ownership Type Indirect and the holding company named in Intermediate Entities
- C.She is left out
- D.Twice, once directly and once indirectly
Show answer
Answer: B. She is the owner, with Ownership Type Indirect and the holding company named in Intermediate Entities
A beneficial owner is always a real person. Indirect and Intermediate Entities describe the path between her and the company.
2. What does Max chain depth: 2 levels tell you?
- A.Two people own the company
- B.At least one owner is separated from the company by one intermediate entity
- C.The register was filed twice
- D.Two owners are politically exposed
Show answer
Answer: B. At least one owner is separated from the company by one intermediate entity
A direct owner is one level. Each intermediate entity adds a level. Deeper chains deserve a closer look.