Beneficial Ownership Chart: Trace Direct and Indirect Holdings

Build the chain from supported links

Give each entity and person a stable identifier, then record every ownership link with its percentage, share class, source and effective date. Start from the applicant and work upward. Label missing or disputed information explicitly. Similar company names are not enough to merge two entities into one node.

FATF's beneficial-ownership guidance supports adequate, accurate and current information from multiple relevant sources. Compare company-provided information with appropriate independent records where policy requires it. Retain discrepancies as review items rather than selecting whichever source produces the simplest chart.

Calculate simple indirect interests transparently

For a simple non-circular ownership chain with ordinary proportional interests, multiply fractions along the path. If a person owns 60% of Holding H and H owns 80% of Applicant A, the person's indirect economic interest in A is 0.60 × 0.80 = 48%. Label this as a calculation of the stated interest, with its assumptions.

Where a person has genuinely distinct direct and indirect paths, show each path before combining applicable interests. Check that the structure does not double-count the same underlying shares. Circular holdings, nominees, trusts, options, special share classes or agreements can require a different analysis. Escalate complexity instead of applying the simple multiplication formula mechanically.

Review control beyond the percentage

Voting rights, appointment rights, agreements and other means of effective control may differ from economic ownership. FATF's legal-person guidance discusses ownership and control as related but distinct considerations. Do not declare that a person below a guessed threshold is irrelevant, or that the largest shareholder is necessarily the only relevant person.

The relevant jurisdiction, entity form and policy determine the applicable tests and evidence. Record the reviewer, rules applied, unresolved control questions and the decision date. A chart that totals 100% can still be incomplete if it omits who directs a nominee or exercises control through another arrangement.

Worked example: a two-tier ownership chart

Fictional Applicant A is owned 80% by Holding H and 20% directly by Person C. H is owned 60% by Person A and 40% by Person B. The stated economic interests in Applicant A are 48% for A, 32% for B and 20% for C, totaling 100%. The reviewer separately asks about voting agreements and appointment rights; the calculation does not answer those questions.