In certain specific cases, a person or persons belonging to the senior management staff may be listed as UBO(s) (the ‘Pseudo-UBO’). For example, if there is no UBO on the basis of shares, voting rights or ownership. This also applies to listed companies. This arrangement guarantees that a UBO can be registered for every legal entity. The designation of the senior management staff is a last resort option and can only be done after exhaustion of all possible means of identifying the UBO and provided that there are no grounds for suspicion, or if there is any doubt as to whether the UBO is indeed the ultimate owner or has control.

For the purposes of the concept, ‘senior management staff’ must mean the statutory management of the client.