Beneficial ownership verification that finds every 25% owner through every layer, with the math and the proof on file
Every owner found through every layer, with the math and the proof on file.
See one case, screen by screen ↓Beneficial ownership verification is how a bank identifies and verifies each person who owns 25% or more of a legal-entity customer, directly or indirectly, and one person who controls it, under the FinCEN CDD Rule (31 CFR 1010.230). Beneficial Ownership Verification does this work with seven agents: they read the certification and the entity's documents, build the ownership tree twice on two models, write out each person's math with its sources and verify each owner's identity. A KYC analyst records the decision and a QC reviewer approves it.
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Beneficial ownership verification starts with the customer's own arithmetic. Under the FinCEN CDD Rule a bank must identify and verify everyone who owns 25% or more of a legal-entity customer, directly or indirectly, and one person who controls it. The customer signs a certification, and customers usually count the stakes they hold directly. A person who reaches 25% through a family holding company is easy to miss, because the form does not ask anyone to multiply.
So the KYC analyst draws the chart by hand. For a layered entity that means the operating agreement, each member's own agreement, the membership ledger, the cap table and registry extracts, then multiplying along each path on paper or in a spreadsheet. Nobody checks that arithmetic until QC, sometimes after the account is open, and the file rarely says why each person was or was not identified. Since March 2025 domestic companies no longer report their owners to FinCEN, so the bank's own file is the record, and since February 2026 FinCEN's relief order lets a bank verify once at the first account. That file has to be right.
Estimated split of the people's working time on one certification with at least one layer of indirect ownership, by hand and with the agents. It leaves out the time spent waiting on the customer. Our arithmetic, kept modest.
Seven agents read every document, build the tree twice and check the certification; the analyst decides and QC approves.
Pellridge Hospitality Group LLC, a Georgia LLC that runs nine boutique hotels, applies to Corvane National Bank for an operating account and treasury services. Its President and COO, Renee Castellanos, certifies one 25% owner, Daniel Pellridge at 34%, and herself as control person. Here is what happens next in the working solution.
Naomi's queue holds four lanes: 23 need her, 71 are ready to record, 14 are waiting on customers and 10 are with QC. Each row is one sentence the agents wrote: Pellridge's missing owner, Brightwater Cold Storage's ownership loop putting Hollis Brandvold at 26.1%, and Arbor & Vine, where the two agents disagree. Three files are due by 5:00 p.m., and Ashgrove Builders is past its service level and escalated.
October so far: 812 certifications, 98.6% decided on time, 41 discrepancies found before opening.
The Document Reader agent has read 9 documents and found 10 stakes and 6 holders. The Ownership Builder agent built the tree, 3 layers deep, and the Ownership Checker agent recomputed every percentage from the documents on a different model. Every arrow carries its stake and a source chip, and each person shows the multiplication: Marisol Ortega holds 18% directly plus 60% of Ortega Family Holdings, which holds 15%, so 18% + 60% × 15% = 27.0%.
“Both agree to the decimal · 6 of 6 holders · tolerance 0.05 pp.”
Each person sits on one row: certified, evidence, working and result. Daniel Pellridge at 34% agrees, and the control person agrees. Marisol Ortega is not listed but holds 27.0%. Tomas Ortega, Annika Voss, Corin Halloway and the employee trust sit below 25%, each with the working recorded.
The note on screen: the bank cannot rely on the certification as signed, because its own documents show a 25% owner who is not on it.
The Outreach agent drafted the letter to Renee Castellanos at 10:16 a.m.: add Marisol Ortega at 27%, explained from Pellridge's own operating agreements, with identity details asked for her only. Naomi submitted it at 10:20 a.m. Desmond approved it at 10:31 a.m., and it went through the client portal at 10:33 a.m. with Elliot Brandt, the relationship manager, copied.
The agent's checks: one person to add, the customer's own documents only, no internal or restricted information, plain language.
Renee signs the corrected certification naming Daniel Pellridge at 34% and Marisol Ortega at 27%. At 2:49 p.m. the agents compare it with the tree: 2 of 2 owners match and the control person is unchanged. The next step on the screen is one button: record the verification decision.
Daniel Pellridge, Renee Castellanos and Marisol Ortega each show the four identity elements: name, date of birth, address and ID number. Dates of birth and ID numbers are masked, and a reveal asks for a reason. Marisol's address is marked Explained, because the identity service still had her prior address until Aug 2026. OFAC screening finds no match for the people or the entities.
Match scores 0.99, 0.98 and 0.97 · OFAC lists of Thu Oct 22, 6:00 a.m.
Naomi records the decision: Verified, reason code BV-02, corrected certification received and matches, with the evidence checklist at 7 of 7. Desmond approves at 3:18 p.m. Only then are 2 beneficial owners and 1 control person written to the client lifecycle system and the core banking system, inside the 2-day service level.
The person who records a decision can never approve it.
Five versions run from “As certified” on Tue Oct 20 at 4:02 p.m. to “Approved and written” on Thu Oct 22 at 3:18 p.m. Each says what changed, why and by whom, and the tree can be exported as of any date. It is kept until 5 years after the account closes.
Every action by people and agents is on the audit trail with its evidence and reason. The examiner pack collects the 9 documents and every tree version, masks dates of birth and ID numbers, attaches each decision with its maker and checker, writes the trail and seals it: 46 pages and a CSV with a fingerprint. Internal audit and BSA Officer packs sit alongside.
Five people at Corvane National Bank who carry one certification: what their week looked like, and what it looks like now.
Seven agents read every document, build the tree twice and check the certification; the analyst decides and QC approves.
Reads the certification, operating agreements, membership ledgers, cap tables, trust agreements and registry extracts, and extracts each stake and officer designation with its exact passage and page.
Builds the ownership tree and computes each person's effective ownership through every layer: it multiplies along each path, adds the paths, solves loops exactly and writes the working out.
Recomputes every effective percentage independently, from the documents, on a different model, and compares its result with the Builder's only after its own is written.
Flags circular ownership and solves the loop, nominee signs such as one registered-agent address behind several entities, trusts and their trustees, and articles that allow bearer shares.
Verifies each person to identify with the CIP elements, screens people and entities against OFAC, and explains each discrepancy.
Decides, for an existing customer opening another account, whether FinCEN's 2026 relief order means no re-verification is owed, and records the customer's confirmation and the reason.
Drafts the request for a corrected certification in plain words and reads the customer's reply on arrival, comparing it with the tree.
Records; a QC Reviewer approves. The agents propose; a named person decides.
Ask about a person, a percentage or a deadline, or say what to prepare. Every answer points to the document and the rule.
Why is Marisol Ortega above 25%?
She holds 18% of Pellridge directly and 60% of Ortega Family Holdings, which holds 15% of Pellridge. 60% × 15% = 9%, and 18% + 9% = 27.0%. The rule counts ownership held directly or indirectly. The Checker agent reached 27.0% on its own, from the same documents.
Why isn't Tomas Ortega identified?
Tomas holds 40% of Ortega Family Holdings: 40% × 15% = 6.0% of Pellridge, below the 25% line. Pellridge is rated moderate risk, so Corvane's 10% line for high-risk customers does not apply. The working is recorded with reason code BV-03.
What if Pellridge were rated high risk?
Corvane's procedure lowers the line to 10% for high-risk customers. Annika Voss and Corin Halloway, at 10.5% each, would then be identified and verified, and the trust at 12% would be reviewed through its trustee. Tomas Ortega, at 6.0%, would stay below the line.
Which certifications are due today?
Three by 5:00 p.m.: Pellridge Hospitality Group, with an owner missing; Brightwater Cold Storage, whose ownership loop puts Hollis Brandvold at 26.1%; and Arbor & Vine Restaurants, where the two agents disagree on Colm Rafferty. Ashgrove Builders is past its service level and with the team lead.
12 screens from the working solution, on its sample data. Pick one to see it large.
The lines, tolerances and clocks every certification is checked against are settings. Each change is a new version with its author, and thresholds need the BSA Officer.
| Setting | Default | Choose from |
|---|---|---|
| Ownership line | 25% | 25% · 20% (it can be lowered, never raised) |
| Line for high-risk customers | 10% | 10% · 15% · 20% |
| Two computations must agree within | 0.05 percentage points | 0.05 · 0.01 percentage points |
| Look through every layer | On, locked | No depth limit; loops are solved, not cut |
| Certification to approved decision | 2 business days | 1 · 2 · 3 business days |
| Escalate to the team lead | 4 business hours left | 4 · 8 business hours |
| Customer reminders | 2 and 5 business days | 2 and 5 · 3 and 7 business days |
| Mask dates of birth and ID numbers | On | On · Off; a reveal asks for a reason and is logged |
Every figure is labelled: a target the solution is built to, an estimate, a typical published result, or a proven one.
“demo” = seen in the working solution, on its sample data · “target” = the design goal, measured in the live solution · “estimated” = our estimate · “typical” = published figures (a 2024 industry survey of corporate treasurers: 41 days on average to open a business account, 87% having abandoned an application; FinCEN's regulatory flexibility analysis for the CDD Rule: about 20 minutes per new legal-entity account). Rules named for context: the FinCEN CDD Rule, 31 CFR 1010.230 (25% owners, one control person, five-year records); the CIP rule, 31 CFR 1020.220; FinCEN exceptive relief order FIN-2026-R001 (February 13, 2026); FinCEN's interim final rule on beneficial ownership information reporting (March 2025). Banks, companies, people, cases and identifiers named on this page are fictional: characters and sample data in the working solution.
Beneficial ownership verification is how a bank identifies and verifies each person who owns 25% or more of a legal-entity customer, directly or indirectly, and one person who controls it, under the FinCEN CDD Rule (31 CFR 1010.230). Beneficial Ownership Verification does this work with seven agents: they read the certification and the entity's documents, build the ownership tree twice on two models, write out each person's math with its sources and verify each owner's identity. A KYC analyst records the decision and a QC reviewer approves it.
It multiplies the stakes along each path, adds the paths and rounds only at the end: Marisol Ortega's 18% direct plus 60% of a holding company that owns 15% is 27.0%. A loop is solved exactly, not cut, so at Brightwater Cold Storage a single pass gives 24.0% and the loop gives 26.1%. A second agent on a different model recomputes every holder from the documents, and the two must agree within 0.05 percentage points.
The file is held for an analyst with both workings side by side. At Arbor & Vine Restaurants the Builder reached 25.0% for Colm Rafferty from the operating agreement and the Checker 24.6% from the cap table dated Sep 1, which does not show units issued to him on Aug 28. The analyst chooses the governing document, the agreement or the cap table, or asks the customer, records a reason and an override code, and QC approves.
The certification is compared with the evidence, person by person, with each difference in plain words. The Outreach agent drafts the corrected-certification request from the customer's own documents, a QC reviewer approves it before it is sent, and the reply is read and compared with the tree when it arrives.
Yes, file by file. For an existing customer opening another account, the Relief agent reads the prior verification, the customer's confirmation and any facts that would reopen it, and says whether re-verification is owed under FIN-2026-R001 of February 13, 2026. Any red flag, a refused confirmation or a high risk rating means re-verify, and an analyst confirms every determination or overrides it with a reason.
Under the CDD Rule, the trustee counts for the ownership prong. The Structure Risk agent finds the trust and its trustee in the documents: at Fairhaven Dental Partners the Lindqvist Family Trust holds 40%, so its trustee, Elena Lindqvist, must be identified and verified.
Yes. The agents propose, show their working and cite their sources; they never settle an owner alone, never send anything to a customer without approval, never clear a potential OFAC match and never decide risk. The KYC Analyst records every decision, a QC Reviewer who did not make it approves it, and the BSA Officer approves threshold changes.
The Agentic Solution Engine builds and deploys it from your requirements and documents: your CDD procedure, your reason codes and a sample of past certifications and entity files. It goes live once every quality gate has passed. We will walk you through it on your own certifications first.
CIP exceptions cleared in minutes, each with its reason and its sources on file.
1-min demoEnhanced Due Diligence (EDD) ReviewEvery EDD file a cited memo, with activity checked against what the customer declared.
1-min demoPerpetual KYC (pKYC)Every customer file kept current every day, with only the sections that changed refreshed.
1-min demoWe'll run Beneficial Ownership Verification on a sample of your own past certifications and entity documents.