In short: Enhanced due diligence is the deeper investigation a regulated firm runs on higher-risk customers, and beneficial ownership resolution is the part of it that traces who ultimately owns or controls a company. Zyphe runs both as an operated desk: agents map the corporate structure, walk each layer through the registries until they reach natural persons, screen those people against sanctions, PEP and adverse media sources, and assemble the file with the gaps stated rather than glossed. Your team sets the customer's risk profile and decides on the relationship, both of which AMLR Article 18(3) reserves to your firm.
Desk description last reviewed 2026-08-20.
What arrives at this desk?
The work this desk takes off your team, stated as the queue it actually receives.
High-risk onboarding
Corporate customers whose jurisdiction, sector or structure puts them into enhanced due diligence before you can onboard them.
Complex ownership structures
Multi-layer holdings, cross-border chains, trusts and nominee arrangements, where the answer is several registries away from the customer you are looking at.
Periodic refresh
Existing corporate customers due for review, where the question is what has changed in the ownership since the file was last built.
Trigger events
A change of control, a new director, a designation touching someone in the chain, or a filing that contradicts what you hold.
How does the UBO and EDD review desk work?
Five steps, the same way every time, because consistency is what an audit is actually testing for.
- 1
Map the structure
The agent establishes the immediate corporate picture from the registry of incorporation: entity status, directors, filed shareholders, and the identifiers that let the next layer be traced.
- 2
Walk the chain to natural persons
Each corporate shareholder is followed through its own registry, layer by layer, until the chain reaches natural persons or reaches something that cannot be resolved. Zyphe runs registry checks against 240+ corporate registries worldwide.
- 3
Apply your ownership threshold
Zyphe defaults to a 25% beneficial ownership threshold, configurable per risk tier, and records control exercised by other means where the shareholding alone does not capture it.
- 4
Screen everyone the chain produces
Every natural person identified is screened against sanctions, PEP and adverse media sources, and the results are attached to the position they hold in the structure rather than to a flat list of names.
- 5
Document what did not resolve
Opaque layers, nominee arrangements, registries with no public filing and contradictions between sources are written into the file as open items. A gap recorded is defensible at audit. A gap smoothed over is not.
What we prepare, and what you approve.
Agent-prepared, human-approved is not a hedge in the marketing copy. It is the shape EU law requires, and it is the reason this desk can be bought by a regulated firm at all.
| Stage | The agent prepares | Your team approves |
|---|---|---|
| Ownership chain | Traces the structure, cites each registry source, and records what could not be resolved | Accepts the chain as sufficient, or sends it back for more |
| Screening results | Screens each natural person found and drafts the disposition | Approves the dispositions |
| Customer risk profile | Assembles the full evidence base | Sets the risk profile for the corporate customer AMLR Art. 18(3)(c) |
| The relationship | Delivers the completed EDD file | Decides whether to enter into or continue the relationship AMLR Art. 18(3)(d) |
| Suspicious activity | Drafts the narrative from the structure and the findings | Decides whether to report, and files with the FIU AMLR Art. 18(3)(e) |
Why the split is drawn there
Article 18 of Regulation (EU) 2024/1624, the EU anti-money laundering regulation that applies from 10 July 2027, permits obliged entities to outsource tasks to service providers, and requires the supervisor to be notified before the provider starts. Article 18(2) then treats the service provider as part of the obliged entity, leaves the entity fully liable, and requires it to be able to demonstrate to its supervisor that it understands the rationale behind the activities the provider carries out. Article 18(3) lists tasks that cannot be outsourced under any circumstances. Every one of them sits on your side of this table.
That demonstrability requirement is the reason each case leaves this desk with its reasoning written out rather than with a score. A confidence number cannot be explained to a supervisor. A rationale can.
What this desk will not do
- Set your beneficial ownership threshold or EDD triggers
- Decide the corporate customer's risk rating
- Approve or reject an onboarding
- Declare an unresolved chain resolved
- File a suspicious activity report on your behalf
What do you actually receive?
A decision-ready file, in the systems you already run.
- An ownership chain traced to natural persons, with each layer cited to its registry
- Screening results attached to positions in the structure, not to a flat name list
- Open items stated explicitly, with what was tried and what blocked it
- An EDD file your reviewer can approve without rebuilding the work
The software behind this desk
If you would rather run the work yourself than have it operated, these are the same capabilities as a product surface.
Frequently asked questions about UBO and EDD review.
What is enhanced due diligence?
Enhanced due diligence is the additional investigation a regulated firm carries out where the money laundering or terrorist financing risk is higher than standard. In practice it means going further on source of funds and source of wealth, resolving ownership and control properly rather than accepting a filed summary, screening the people behind the structure, and documenting the reasoning at a level that survives a supervisor reading it later.
When is EDD required?
The common triggers are a customer or transaction connected to a high-risk third country, a politically exposed person or a close associate of one, an unusually complex or opaque ownership structure, and any situation your own risk assessment classifies as high risk. The specific triggers belong in your policy, and under AMLR Article 18(3)(b) the approval of that policy is not something you can hand to a service provider.
What is a beneficial owner, and what threshold applies?
A beneficial owner is the natural person who ultimately owns or controls the customer, whether through shareholding, voting rights, or control exercised by other means. Zyphe defaults to a 25% beneficial ownership threshold, configurable per risk tier, in line with the EU framework that applies from 10 July 2027. Ownership percentage is not the whole test: control can sit with someone whose shareholding is below any threshold.
What happens when the ownership chain cannot be resolved?
It gets written into the file as an open item, with what was attempted, which registry or source blocked it, and what would resolve it. The desk does not close a chain it could not trace. Whether an unresolved chain is acceptable is a risk decision, and that decision is yours: AMLR Article 18(3)(c) reserves the customer risk profile to the obliged entity.
Do you replace our KYB provider or registry access?
The desk can work on top of what you already have, or run the registry checks itself against 240+ corporate registries worldwide. The distinction that matters is not who holds the registry connection, it is who does the reading, the chain-walking and the file assembly. That is the part this desk takes.
The other desks
Most teams start with one queue and add the next once the first is clearing.
Sanctions and PEP alert review
Works the screening queue your engine produces: compares each hit against your matching policy, writes the disposition and its reasoning, and escalates the ones that are genuinely unclear.
See the deskAdverse media review
Reads the underlying coverage rather than the headline, resolves whether the story is actually about your customer, classifies it against your risk taxonomy, and summarises with citations.
See the deskTransaction monitoring alert triage
Reconstructs the account history behind each rule-triggered alert, tests it against that customer's own baseline and your typologies, and drafts either a reasoned close or a narrative your investigator can amend and file.
See the deskKYC periodic review and refresh
Re-runs the checks on customers falling due, compares what it finds against the file you already hold, and reports what actually changed rather than rebuilding a dossier nobody reads.
See the deskBook a demo
Put the UBO and EDD review queue on a desk.
Book a demo and bring a real slice of your queue. We will work it, show you the files, and you will see exactly what your team still has to approve.