Who is a beneficial owner?

The actual beneficial owner (BO) is a natural person:

1. who has ultimate controlling influence over a natural or legal person through ownership or other means of control, or;
2. in whose interest, benefit or name the transaction or operation is performed.

The beneficial owner of a company is a natural person whose direct or indirect participation or the sum of all direct and indirect participations in the company exceeds 25 percent, including participations in the form of bearer shares or parts or in other ways.

If, after all possible identification methods have been exhausted, it is not possible to identify the named person, and provided that there is no reason to suspect the existence of such a person, or if there is doubt as to whether the identified person is the actual beneficiary, the actual beneficiary shall be deemed to be a natural person who is a member of the higher management body member. In addition, the person or persons exercising factual control over the company, who make strategic decisions in the company or, in the absence of such persons, perform daily and regular management, are actual beneficiaries.