UBO & Pseudo-UBO requirements

Key definitions #

UBO (Ultimate Beneficial Owner) #

A UBO is the individual who ultimately owns or controls a company, typically:

• Owns ≥ 25% of shares or voting rights
• Statutory director (if control applies)
• Anyone with effective control

Pseudo‑UBO / Authorised Representative #

When no UBO can be identified, a senior manager is designated by default.

• No one owns ≥ 25% or exercises control
• A senior manager is named as UBO for compliance purposes

Why is this required? #

Nuvei for Platforms must identify and verify UBOs due to EU and Dutch AML regulations (4MLD/5MLD, Wwft).

Process steps #

Step 1 — Identification #

• Identify UBO(s) or, if none can be found, designate a pseudo‑UBO.
• Output: list of relevant individuals.

Step 2 — Data collection #

• Name, date of birth, nationality, address
• Ownership and control details
• ID and supporting documents
• Company and UBO register extracts
• Output: complete evidence set.

Step 3 — Submission #

Submit details via Hosted Onboarding.

Output: onboarding case submission.

Step 4 — Verification #

• Identity and ownership checks
• Sanctions/PEP screening
• Consistency with official records
• Output: pass / more info needed / fail.

Step 5 — Approval #

The entity is approved if all checks are successful; otherwise, more information or remediation is required.

Output: approved status or follow‑up.

Step 6 — Ongoing maintenance #

Keep UBO/pseudo‑UBO information updated and notify Nuvei for Platforms of any changes promptly.

Output: updated records.

Implications for UBO / Pseudo‑UBO #

• Disclosure: identity and control details are collected.
• Verification: AML screening may apply.
• Documentation: a valid ID is required.
• Traceability: information must match official records.
• Accuracy: incomplete information delays onboarding.

Handling internal changes #

When to update #

• Shareholding crosses the ≥ 25% threshold
• A new significant shareholder is added
• Control structure changes
• Director or senior management change (for pseudo‑UBO)
• Corporate restructuring

Required actions #

• Update the UBO register
• Obtain an updated company/UBO extract
• Submit updates via Hosted Onboarding
• Provide new IDs and documents
• Nuvei for Platforms will re‑verify

If not updated #

• Onboarding delays
• Possible processing restrictions

Roles & handoff #

Roles #

Simple handoff #

1. Partner identifies UBO or pseudo‑UBO
2. Submits via Hosted Onboarding
3. Nuvei for Platforms verifies/approves or requests more information
4. Partner submits updates as needed