Ultimate Beneficial Owners (UBOs)

An Ultimate Beneficial Owner (UBO) is an individual who has ultimate effective control over a business, by means of controlling ownership of the highest level parent company within their corporate structure.

FullCircl's UBO information is gathered by connecting ownership across companies within a corporate family to provide a true view of ownership. We calculate this by looking at both shareholdings and Persons of Significant Control (PSC) details of the viewed company, then in the case of any parent/shareholder companies, looking at the same for them as well until reaching the top level individual owners. Our UBO data will display any resulting owners with 10% or higher total ownership.

In the case of 100% owned subsidiary companies their UBO details will mirror their parent, but where a company is owned by two or more companies their UBOs will be split accordingly. For example:

• A business has two parent companies each owning 50%, and each of them has two shareholders owning 50%. All four ultimate owners will be displayed as 25% UBOs.
• If one of these businesses has a single shareholder, the UBOs would indicate them with 50% ultimate control (50%/25%/25%)
• If shares are broken down in a less even manner, for example 75/25, this too will be reflected accordingly (25%/25%/32.5%/17.5%).

UBO information for a company can be observed from the "Ownership" section of the company's Data page. We also offer a UBO data module within our Commercial API product - please see the following link to our API Documentation site for more details. UBOs

Ownership data anomalies

Anomaly results are flagged against UBOs where our data is unable to provide an accurate figure for the ultimate beneficial owner(s) of a business. Our UBO data can encounter anomalies for several reasons, such as:

• Ownership conflict:
  • Inconsistent information regarding shareholdings from different sources (shareholdings/PSCs of both currently viewed company and/or its parents)
  • Total ownership exceeds 100%.
  • Outdated information not aligning with updated documentation
• Ownership incomplete:
  • Total ownership does not reach 100%



Any potential conflicts, due to data conflicts or incomplete data, will be displayed as-is but flagged as an anomaly. Multiple anomalies can be flagged against shareholder/PSC UBOs at a given time, so the total number of anomaly flags may exceed the number of UBOs visible.

In a case where a subsidiary's ownership details do not match their parent organisation, a combination of all information will be used. and an ownership conflict anomaly will be flagged. The UBO algorithm will not pick and choose which of the available ownership sources are perceived to be more accurate, and as such the anomalous owners for the subsidiary will be listed as UBOs alongside the factual ones from their ultimate parent organisation.

If you are unsure of the cause of any anomalous records, please raise this with our Support team via the Help options within our web app, or by email at [e-mail].