Beneficial owner — who it is and how to establish it.
Beneficial owner — who it is and how to establish it.
A natural person who controls the client: directly, indirectly or through other rights. The threshold is 25% of shares or votes — but that is only the start.
- Sanctions: MSWiA, EU, OFAC
- KNF warnings
- Beneficial owners (CRBR)
- Financials and filings
- Bankruptcy, liquidation, KRZ
- VAT status and accounts
- Press coverage
- 0–100 risk score and PDF
Money back if the report cannot be generated
For companies: the first 2 reports free (in Polish)
What the Act says
A beneficial owner is any natural person who directly or indirectly controls the client through rights that allow a decisive influence over its actions, or the person on whose behalf a relationship is entered into or a transaction carried out (art. 2(2)(1) of the AML Act). For a company — a legal person other than one listed on a regulated market — the Act names explicitly:
- a natural person holding more than 25% of the total number of shares;
- a person with more than 25% of the total votes, also as a pledgee, usufructuary or under agreements with other holders;
- a person controlling a legal person or persons that together hold more than 25% of shares or votes;
- a person exercising control within the meaning of accounting law (a parent entity);
- where none of the above can be established and there is no suspicion of money laundering — the person holding a senior management position.
Separate definitions cover trusts (settlor, trustee, protector, beneficiary) and natural persons running a business — there the owner is the trader, unless something points to control by someone else.
Companies entered in KRS file their owners with the Central Register of Beneficial Owners (art. 58–59) and update the filing within 14 days of a change. An obliged entity that finds a discrepancy between the CRBR and its own findings reports it to the authority keeping the register (art. 61a). Full text: isap.sejm.gov.pl.
How to establish the owner in five steps.
Shareholders from KRS
Pull the current extract and the shareholder list. Every natural person with more than 25% of shares or votes is an owner. Check preferred shares and shareholder agreements where disclosed.
If a shareholder is a company — go up
For each corporate shareholder pull its own shareholders and multiply: 60% × 50% = 30%, above the threshold. Repeat until you reach natural persons or a listed company. For a foreign shareholder, use its home register.
Compare with the CRBR
Set your own analysis against the CRBR filing: the same people, the same holdings, the same nature of rights. No filing at all is a signal too.
Sanctions and PEP for each one
Screen every established owner against sanctions lists and for PEP status — whether or not they appear in the CRBR.
Discrepancy? Report it
If your findings differ from the CRBR, ask the client to explain, and as an obliged entity report the discrepancy with reasons (art. 61a). Record the result and date in the file.
A worked example
Client: Alfa sp. z o.o. Direct shareholders: Beta sp. z o.o. (60%) and Jan K. (40%). Beta is owned by Gamma s.a. (50%) and Anna M. (50%). Gamma is owned by Piotr W. (80%) and Marta L. (20%).
| Person | Path | Effective holding | Owner? |
|---|---|---|---|
| Jan K. | direct 40% | 40% | yes |
| Anna M. | Beta 60% × 50% | 30% | yes |
| Piotr W. | Beta 60% × Gamma 50% × 80% | 24% | not by shares — check control over Gamma |
| Marta L. | Beta 60% × Gamma 50% × 20% | 6% | no |
Piotr W. holds 24% effectively, but controls Gamma (80%), and Gamma co-controls Beta, which holds 60% of Alfa. If the Gamma or Beta agreements give him the say over their votes, he is an owner through "control over a legal person". The arithmetic is the start; rights are the second half.
Four mistakes in establishing the owner.
Each ends with the wrong person in the file — or no person at all.
How the report helps
The complete AMLA dossier shows the CRBR owners and the KRS shareholders side by side and unfolds the ownership structure to two levels by default, computing effective holdings through the chain. Discrepancies between the registers — a different person, a different holding, no filing, an outdated filing — are flagged in the "Structure and UBO" domain with points and the source, and for each one the report attaches a draft discrepancy notice to the CRBR.
Every established person is screened against sanctions lists; obliged entities that make a declaration also see PEP and RCA status. Persons whose KRS data is published in masked form are not screened automatically, and the report says so. A foreign shareholder is shown with its name and country; its further structure is not unfolded — that has to be established with the client.
See also: CRBR lookup, beneficial owners in the report, customer identification. Scoring rules: methodology.
Legal status as of October 2026. Information only, not legal advice.
Structure and owners are in the full report.
The free check shows the company's register data. Shareholders from KRS, owners from the CRBR, effective holdings and discrepancies are in the AMLA dossier.
Questions about the beneficial owner.
Establish the owner by NIP.
Shareholders from KRS, owners from the CRBR, effective holdings and discrepancies — in one PDF report, in up to 3 minutes.