KYB Entity Roles: Applicant, Owner and Authorized Signer

Start with the applicant and relationship

Identify the legal entity that will hold the account or sign the service agreement. Record its exact name, registration identifier, jurisdiction, legal form and relevant trading names. A website brand may differ from the contracting company. Link the application to the intended products and activities so the reviewer understands what relationship is being assessed.

FATF Recommendation 10 describes identifying the customer, understanding ownership and control and understanding the intended relationship. The operational role map supports those tasks, while the applicable local rules and approved policy determine the exact verification obligations. It does not replace the separate document checklist for a particular onboarding process.

Separate ownership, management and authority

A registered shareholder is the holder recorded for a particular ownership interest. A director has a management or governance role under the relevant framework. An authorized signer acts under a specific authority. A beneficial owner is ultimately a natural person who owns or controls the entity under the applicable analysis; a holding company should not be treated as the final person simply because it owns the shares.

FATF's glossary makes the distinction between natural persons and intermediate legal entities explicit. Record each relationship with its evidence, effective date and limitations. One individual may occupy several roles, but each role still needs a reason. A passport verifies identity evidence; a separate corporate authorization may be needed to support signing authority.

Resolve gaps without collapsing the roles

If the application names a signer who is absent from public director records, request the appropriate authority evidence under policy rather than assuming fraud or rejecting the person solely for that difference. If an ownership link is missing, keep the chart incomplete and assign a review task. Do not fill an unknown owner field with the most convenient contact.

Version the map when ownership, directors or mandates change. Preserve the previous state and the date the new evidence was obtained. Limit access to identity records and retain references in the operational map. A completed role map supports a review; it does not itself approve the applicant or establish permission for its proposed business.

Example: four roles, three people

In a fictional application, Cedar Trading Ltd is the customer. Person A owns 70% and Person B owns 30%; both ownership links require verification under policy. Person B is also a director. Person C, a finance employee, is the proposed signer under a documented mandate. Person C's authority is checked independently of A and B's ownership. No ownership threshold or automatic approval rule is implied.