Step 1
Send the client's tax number
The tax number from the application form, the counterparty card or the account opening request. The request goes to the API from your system.
Identifying a company's beneficial owners: a UBO check for compliance
Finding the beneficial owners of a corporate client (the ultimate beneficial owner, UBO) starts with whoever stands behind the company in the register. From a tax number NeuroVision pulls the director and the members with their stakes from the state register and checks every person: the Rosfinmonitoring watchlist, sanctions, PEP lists, bankruptcy, nominee status. The result comes back in JSON — into your client file.
Data is stored in Russia Russian Software Registry No. 19972 Compliance with 152-FZ and 115-FZ
A beneficial owner questionnaire and document checks for owners by link — in KYB early access. Leave a request to be among the first to connect.
What a NeuroVision UBO check covers
A UBO check is two tasks: find out who owns the company, and make sure those people can be worked with. The register partly answers the first; checks on each person answer the second. Below — what works today, and what comes with KYB early access.
- The director (the sole executive body) with their tax number
- The members of a limited liability company who are individuals, with the size of their stake
- Corporate members with their tax numbers — for the next step along the chain
- The company's status: active, liquidation, reorganisation
- Links between the director and the members and other companies
- The list of terrorists and extremists
- Sanctions lists
- PEP, sanctions from 50+ countries and adverse coverage — 36 ₽
- Nominee or serial director
- Personal bankruptcy
- Commercial court cases, including bankruptcy
- The foreign agents register
- Tax arrears and account freezes
- A beneficial owner questionnaire: the representative names the owners with a stake above 25% and the controlling persons
- Every owner gets a personal link to have their identity document checked
- Indirect stakes calculated along the chain of corporate members
- Foreign members — against overseas company registers
- Monitoring of ownership changes and of appearances on lists
- A single report on the company and its owners
- Checking owners and the director: a search by name may turn up namesakes — the results are split into exact matches and likely namesakes. Checks by tax number carry no namesakes. Each check costs 5 ₽ and is switched on separately.
- Early access — KYB platform features connected on request. Your manager will confirm the timing.
Who identifies beneficial owners under 115‑FZ, and why
It is not only banks that identify a client's beneficial owner. A company must know its own beneficial owners too, and organisations named in article 5 of 115‑FZ have a separate duty — to identify the beneficial owners of every corporate client.
Identification is not carried out where the client is a state body, an organisation more than 50% state-owned, an international organisation or an issuer that discloses information, and in the other cases listed in art. 7, cl. 1, item 2. NeuroVision provides the data and the check results — who the client's beneficial owner is is decided by your compliance team under its internal control rules.
- An article on UBO
Whom the law treats as a beneficial owner
115‑FZ, art. 3 — the beneficial owner.
By ownership
- An individual who ultimately, directly or indirectly through third parties, owns the corporate client — holding a predominant stake of more than 25% in its capital
By control
- Or who is able to control the client's actions
The two criteria are independent
- A person with a 10% stake may be a beneficial owner by control, while exactly 25% does not clear the ownership threshold
- Choose the checks
Organisations: identify your clients' beneficial owners
115‑FZ, art. 7, cl. 1, items 2 and 3; art. 7.1.
Who is covered
- Organisations named in art. 5 of 115‑FZ — banks, microfinance companies, insurance and leasing companies, payment system operators, brokers and others
- For certain transactions — advocates, notaries, accountants and auditors (art. 7.1)
What to do
- Take reasonable steps available in the circumstances to identify the client's beneficial owners — when the client is taken on
Update
- At least once a year; for low-risk clients — once every three years; where there is doubt — within seven working days
If none is identified
- The client's sole executive body — usually the chief executive — may be treated as the beneficial owner. That is the organisation's right, not an automatic rule
- 115‑FZ in plain words
Disclosing the ownership structure: what a company must do itself
115‑FZ, art. 6.1; Administrative Offences Code, art. 14.25.1.
Hold and update
- Details of its own beneficial owners — at least once a year, or whenever they change
Keep
- The details and a record of the steps taken — for at least five years
Provide
- On a request from Rosfinmonitoring, the tax authority or the Ministry of Justice (for non-profits) — within the period set by the Government
- A company may request the details from its members, and they are obliged to provide them — this does not breach data protection law
Liability
- A company — from 100,000 to 500,000 ₽; an officer — from 30,000 to 40,000 ₽, or disqualification for up to a year
How a client's beneficial owners are checked
The first steps run from a single tax number, with no involvement from the client. The questionnaire and owner document checks come in when the register is not enough: for joint-stock companies, foreign members and complex chains.
Step 2
Finding owners from the register
The tax number brings back the director and the members with their stakes from the state register. If a member is another company, its tax number can go in the next request and the chain continues.
Step 3
A check on every person
The owners and the director are checked against the Rosfinmonitoring watchlist, sanctions lists, bankruptcy, commercial court cases and nominee indicators. You choose the set of checks yourself.
Step 4
The beneficial owner questionnaire
Early access. The company's representative names the owners with a stake above 25% and the people who control the company. Discrepancies with the state register show at once.
Step 5
Each owner's document
Early access. The owner receives a personal link and uploads their identity document. The data is read and goes into the same checks.
Step 6
The decision and the file
The result for each person — «passed», «not passed» or «no data» — arrives in JSON and by webhook. The answers are kept: they can be attached to the client file and shown in an inspection.
Direct and indirect stakes: a worked example
An ownership structure is stakes multiplied along the chain. An example: the holding company Severny Dvor Holding owns 50% of Severny Dvor LLC, and Fyodor Zakharyin owns 60% of the holding. His indirect stake is 0.6 × 0.5 = 30%: above 25%, so he is a beneficial owner by ownership. Vera Golubeva's direct 20% does not make her one by stake, so control is checked next. Today the stakes at each level come from the state register in separate requests; automatic calculation along the whole chain is in early access.
What the state register shows for different companies, and how to fill the gaps
Finding the ultimate beneficial owner runs up against what the open register actually holds: for a limited liability company the members and their stakes are visible, for a joint-stock company almost nothing is. Either way the details can be requested from the company itself — it is obliged to hold them (115‑FZ, art. 6.1). The job of the check is to match the client's answer against the register and check every person named.
| The client company | What the state register holds | What NeuroVision does |
|---|---|---|
| An LLC whose members are individuals | the members and the size of their stakes | register data plus a check on every member and on the director; early access — the beneficial owner questionnaire for the control criterion |
| An LLC whose member is a Russian company | the corporate member's tax number and its stake | the next request by the member's tax number, with checks on the people at every level; early access — automatic calculation of indirect stakes along the chain |
| A joint-stock company | the share register is not public: the state register holds the registrar and the sole shareholder, if there is only one | a check on the director; shareholders — from the data you obtained from the client; early access — the questionnaire and owner documents by link |
| A member that is a foreign company | the name of the foreign member | a check on the director and on the owners known to you against sanctions and PEP lists; early access — overseas company registers |
| Details of the members are withheld | some of the details may be unavailable | a check on the director; early access — a questionnaire from the company's representative |
Risk signals in an ownership structure
The risk is usually not in the company itself — it is in the people behind it. Six situations a UBO check shows before the deal, not after.
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Nominee director
The director is listed as the head of dozens of companies, or appears on the register of serial directors — a sign that someone else takes the decisions.
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An owner on the Rosfinmonitoring watchlist
If a member or the director is on the list of terrorists and extremists, the client's transactions fall under the freezing (blocking) measures of 115‑FZ.
- Learn more
Sanctions through a stake
Under the OFAC rule, a company owned 50% or more in aggregate by persons on the SDN list is itself treated as blocked, even if it is not on the list.
- Learn more
A politically exposed person among the owners
Foreign PEPs are taken on only by a written decision of the head of the organisation (115‑FZ, art. 7.3). That has to be known at onboarding.
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An owner's bankruptcy and debts
A member in bankruptcy proceedings or with frozen accounts is a reason to look at the company's resilience and where its money comes from.
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No beneficial owner identified
If nobody holds more than 25% and control is not established, the organisation may treat the director as the beneficial owner. The check on them then matters most.
By hand, by questionnaire or through the API: how to choose
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A register extract and manual matching
A free extract from egrul.nalog.ru, every register on the people checked by hand, indirect stakes worked out by a member of staff, and the annual update done from scratch. The evidence is screenshots and extracts. Fine for the occasional client.
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A questionnaire from the client
The company's own statement of its owners: indirect stakes as the client reports them, no checks on the people, and an update means a new questionnaire. The evidence is a signed form. A complement to any approach.
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A UBO check through NeuroVision
The state register through the API and, in the same request, watchlists, sanctions, PEP, bankruptcy and nominee indicators for every person. The stakes at each level come by tax number, the annual update is a repeat request, and the API answers carry a date and a source. The questionnaire and chain calculation are in early access.
How to choose: count your corporate clients at onboarding and at the annual update, work out the share of complex structures (joint-stock companies, foreign members, chains), decide where the result lands — a CRM, the core banking system or onboarding — match the set of checks against your internal control rules, and try the scenario on test access. For a one-off check, the free an extract from the state register of legal entities of the tax service will do.
Who needs a check on a company's owners
Organisations named in article 5 of 115‑FZ are required to identify their clients' beneficial owners. Everyone else checks their partners' owners voluntarily — so as not to pay a front company or run into sanctions risk.
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Banks and MFIs
- Beneficial owners when opening an account or lending to a company
- The annual update of the details
- API answers in the client file
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Leasing and factoring
- The owners of the lessee and the debtor before the deal
- Members' bankruptcy and debts
- A repeat check when the members change
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Brokers and payment services
- Corporate clients' owners against watchlists and sanctions
- PEPs among the members
- A check when the director changes
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Marketplaces and B2B platforms
- The owners of a corporate seller before the first payout
- Weeding out nominee directors
- A check across the whole seller base
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Lawyers, notaries, accountants
- A client's beneficial owners in the transactions listed in art. 7.1 of 115‑FZ
- A check on the members before a deal over stakes
- Keeping the check results
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UBO check terms
- UBO
- A company's ultimate beneficial owner — an individual. In 115‑FZ — the «beneficial owner».
- Ultimate beneficial owner
- Direct ownership
- A person's stake in a company's capital, registered in their own name.
- Indirect ownership
- A stake held through other companies; worked out by multiplying the stakes along the chain.
- Supervision
- The ability to determine a company's decisions without a stake above 25% — through agreements, family ties, powers of attorney or de facto management.
- The sole executive body
- The chief executive or a managing company. May be treated as the beneficial owner where none is identified.
- The beneficiary
- The person for whose benefit the client carries out a particular transaction. Not the same as the beneficial owner.
- Nominee director
- A director listed in the register who takes no decisions; the giveaway is heading many companies at once.
- PEP
- A politically exposed person: foreign, from an international organisation, or Russian as listed in the law.
- KYB
- A check on the client company as a whole: register data, documents, owners, the representative.
- Know Your Business
What a beneficial owner check costs
You pay only for the checks carried out, with no subscription fee. The cost of a UBO check depends on how many people stand behind the company and which registers you switch on.
Calculate the cost- 01
A check on an owner or the director — 5 ₽ per register
- 02
PEP, sanctions from 50+ countries and adverse coverage — 36 ₽
- 03
State register data and the full KYB loop — priced on request
Connecting: the API today, the KYB widget — in early access
Terms
- A 1-month trial period
- A dedicated manager
- 24/7 support
- Payment for the checks performed
Licences and certificates
The project «Development of a multimodal system using artificial intelligence "Neuromed" for managing the diagnostic processes of a clinic on the basis of the "Neurovision" computer vision platform» is supported by the Innovation Promotion Foundation within the federal project «Domestic Solutions»
The Neurovision computer vision platform is registered with Rospatent (certificate No. 2023661508) and included in the Russian Software Registry (entry No. 19972 of 13.11.2023)
The right to use the Platform is granted under a licence agreement concluded by Neurovision with its customers
Read also
How the requirements on beneficial owners and company checks work — in our blog.
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115-FZ: What Businesses Are Required to Do and How to Meet the Law’s Requirements
Questions about checking beneficial owners
UBO (ultimate beneficial owner) — a company's ultimate beneficial owner, an individual who owns more than 25% of its capital directly or indirectly, or who controls the company. A UBO check means establishing who those people are and checking them against watchlists, sanctions, PEP lists and other registers. The concept in detail — in the article «The beneficial owner (UBO)».
Organisations named in article 5 of 115‑FZ — banks, microfinance companies, insurance and leasing companies, brokers, payment system operators and others — and, for certain transactions, advocates, notaries and accountants as well (art. 7.1). They take reasonable and available steps to identify beneficial owners and update the details at least once a year, or once every three years for low-risk clients.
For a limited liability company whose members are individuals, the register is often enough: it holds the members and their stakes. For joint-stock companies, foreign members and the control criterion you need details from the company itself. From a tax number NeuroVision gives the state register data and checks every person; the beneficial owner questionnaire is in KYB early access.
A joint-stock company's share register is not public. For a joint-stock company the state register holds the registrar and the sole shareholder, if there is only one. Details of a joint-stock company's owners are requested from the company.
No. A company must hold the details of its own beneficial owners itself, update them at least once a year, keep them for at least five years and provide them on a request from Rosfinmonitoring or the tax authority — within the period set by the Government.
First the control criterion is tested — who actually determines the company's decisions. If no beneficial owner is identified, the sole executive body — usually the chief executive — may be treated as one.
Checking one person against one register — 5 ₽; extended screening against PEP lists and sanctions from 50+ countries — 36 ₽. The total depends on how many people stand behind the company and which registers you choose. State register data and the full KYB loop — on request. There is no subscription fee.
A counterparty check answers «is this company reliable»: status, court cases, debts. A beneficial owner check answers «who stands behind it and can we work with those people». At NeuroVision both start from the same tax number. More on the counterparty check page.
Yes. A repeat request by the client's tax number returns current state register data and fresh check results; changes in the membership show by comparison with the previous answer. Automatic monitoring of ownership changes is in KYB early access.
Under article 14.25.1 of the Administrative Offences Code: a company — from 100,000 to 500,000 ₽; an officer — from 30,000 to 40,000 ₽, or disqualification for up to a year.
Let us talk about checking your clients' beneficial owners
Tell us how many corporate clients you check and what their structures look like — we will put together a set of checks and connect you to KYB early access.
Can't put your request into words? Book a call and our team will contact you at a convenient time
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