Findel UBO Questionnaire

Q: How do I know which sections of the template I need to complete?

The template uses a cascading approach that must be followed in order. Start with Section 1 for Listed Companies. If Section 1 is not applicable (i.e., you select "No"), you must complete both Sections 2 and 3 regarding ownership and control. Only if you answer "No" to Sections 1, 2, and 3 should you proceed to Section 4 about Senior Managing Officials. This is not a choose-one approach - you must follow the sequence and complete all applicable sections.

Q: What documentation needs to be provided with the UBO Declaration?

For any individuals listed in Sections 2, 3, or 4, you must provide a copy of a valid passport or government ID. If you're completing the optional Chain of Ownership section, you need to include an Organization Chart that is dated and signed by valid company representatives. The chart must detail the name, address, registration number, and ownership percentage of all intermediate entities. For EU-based companies, you may also need to provide UBO register documentation if it's not publicly available.

Q: What qualifies as an acceptable address in the template?

The template specifically states that PO Box or C/O addresses will not be accepted. The address must be either the country of current residency for individual UBOs or the actual company address for corporate entities. This requirement applies across all sections where address information is requested.

Q: What if a company is owned by multiple entities that each own less than 25%?

Even if no single owner meets the 25% threshold, you should still examine control through other means in Section 3. If there is no control through other means, you must complete Section 4 to identify the Senior Managing Officials. Remember that the 25% threshold might be lowered to 10% depending on your jurisdiction or the company's risk rating, as noted in the template's footnotes.

Q: How are changes to information handled in this UBO Declaration?

The Declaration section of the template includes a commitment to notify any subsequent changes to Ultimate Beneficial Ownership without delay. All signatories must be in accordance with the Authorised Signatory list. The document requires two authorized signatures, along with names, titles, and dates. Any updates should be submitted using the same template format, ensuring all sections are still completed according to the cascading structure.

The Findel UBO Declaration Template is a standardized form designed to collect and document Ultimate Beneficial Ownership information in compliance with EU AML regulations, particularly the Luxembourg AML Law of 12 November 2004 as amended. This template provides a structured approach to gathering essential information about company ownership, control structures, and beneficial owners.

Templates

Findel UBO & SMO_20221107 Static Template

v1.0.0 · Mar 2026

Findel UBO &SMO Declaration

v1.0.0 · Mar 2026

Findel UBO & SMO_20221107

v1.0.0 · Mar 2026

FAQs

How do I know which sections of the template I need to complete?

What documentation needs to be provided with the UBO Declaration?

What qualifies as an acceptable address in the template?

What if a company is owned by multiple entities that each own less than 25%?

How are changes to information handled in this UBO Declaration?

Terms & Glossary

Beneficial Owner

As defined in article 1(7) of the Luxembourg AML Law of 12 November 2004, any natural person(s) who ultimately owns or controls the customer or any natural person(s) on whose behalf a transaction or activity is being conducted.

Control through Other Means

As specified in Articles 1711-1 to 1711-3 of the Law of 10 August 1915 on commercial companies, includes: direct or indirect right to exercise dominant influence through contracts, majority control of administrative bodies, power to exercise dominant influence, or obligation to prepare consolidated financial statements.

Fiduciaire

The trustee or administrator in a fiducie arrangement (Luxembourg trust equivalent) who holds and manages assets on behalf of beneficiaries.

Intermediate Entities

Companies or legal arrangements placed between the subject company and its beneficial owners in the ownership chain, whose details must be included in the organizational chart.

Politically Exposed Person (PEP)

A current or former natural person entrusted with prominent public functions, including heads of states, senior politicians, government or military officials, or senior executives of state-owned entities, along with their relatives and close associates.

Protector

A person who may be appointed in a trust or fiducie arrangement with certain powers or duties to ensure the trust is properly executed and administered by the trustees/fiduciaires.

Regulated Market

A market for trading financial instruments where a company's shares may be admitted for trading, subject to disclosure requirements consistent with European Union law or equivalent international standards.

Senior Managing Official (SMO)

Any natural person exercising executive control over the daily and regular business of the entity through a senior management position, such as Director, Chief Executive Officer (CEO), Chief Financial Officer (CFO), Managing or Executive Director, President, or Chairman.

Settlor

The person who establishes a trust or fiducie arrangement by transferring assets to trustees/fiduciaires for the benefit of beneficiaries.

UBO Register

The official register for company beneficial ownership information in EU Member States, which may be publicly available or restricted, and must be declared for companies located within EU jurisdictions.