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.
• For organizations without traditional UBOs (e.g. federations, associations, foundations), identify the authorized representative(s) (e.g. director, president, board member, secretary). If they are not identified in the company documentation, an additional signed letter confirming their authority to act on behalf of the organization may be required.
• 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