Our London and Frankfurt offices are onboarding the same client. Can Frankfurt use London's UBO work?

 Yes, potentially, but it cannot simply adopt London's conclusion. AMLR Articles 48–49 allow reliance on CDD performed by another obliged entity, including within the same group where the conditions are met, but Frankfurt retains ultimate responsibility for compliance. It also has to apply the EU UBO test: 25% or more, compared with more than 25% under UK Regulation 5. The underlying evidence can be shared; the UBO determination needs to reflect the rules applying to the office conducting the relationship.

We have a PE-backed client where the fund holds exactly 25% through a Luxembourg SPV. Will London and Frankfurt reach the same UBO conclusion?

Not necessarily. Under UK MLR 2017, exactly 25% does not meet the more than 25% ownership threshold, although the firm must still consider whether anyone qualifies through control. If no individual can be identified after the required checks, the senior-management fallback may apply. (UK MLR 2017, Regulations 5 and 28)

Under the AMLR, 25% is enough to trigger the ownership test. The Frankfurt team must analyse the ownership and control chain through the SPV and fund, applying the AMLR’s specific rules for indirect ownership and, where relevant, collective investment undertakings. (AMLR Articles 51–54 and 61)

The two offices can therefore reach different UBO conclusions from the same structure. That difference alone is not a reportable discrepancy: Article 24 only applies if the EU office’s CDD findings conflict with information in the relevant EU beneficial ownership register.

We have exhausted the ownership structure and still cannot identify a UBO. Can every office just record the CEO?

No. Under UK Regulation 28, once the required steps have been exhausted, the firm may in specified circumstances treat the senior person responsible for managing the company as its beneficial owner and record the steps taken. Under AMLR Article 22, the EU office instead records that no beneficial owner was identified and identifies and verifies all natural persons holding senior managing official positions. That distinction matters in a shared client system: an EU senior managing official should not simply be stored as the client's UBO because that is how the London file handles the fallback.

How does AMLR handle trust UBO identification differently from UK MLRs?

Both regimes capture the core trust parties — settlor, trustees, beneficiaries, protector and anyone exercising ultimate control. The difference is that the AMLR is more prescriptive about complex and discretionary trusts. Articles 58–60 require firms to look through legal entities occupying trust roles, identify classes of beneficiaries where individuals are not yet known, and, for discretionary trusts, identify objects of a power and default takers.

UK Regulation 6 is less granular, defining the relevant beneficial owners without the same detailed rules for multi-layer structures and discretionary beneficiaries. For firms operating in both jurisdictions, that can mean collecting more information about the trust structure for an EU matter.

See our full UK vs EU trust comparison