For bank onboarding, combine three views: a dated legal-ownership chart to natural-person beneficial owners, a control narrative explaining directors and decision rights, and a money-flow map connecting contracts, accounts and expected transactions. Every statement should reconcile to current registry records, corporate documents, the website, tax position and supporting commercial evidence.
What the bank is trying to understand
Customer due diligence is not limited to collecting incorporation certificates. An institution must identify the customer and beneficial owner, take reasonable measures to understand ownership and control, establish the purpose and intended nature of the relationship, and monitor activity against the profile. A chart answers only part of that task.
The reviewer needs to see the economic logic: which company sells, owns IP, employs people, holds investments or receives funding; who can appoint directors or move money; and why the requested account sits in the proposed country. Complexity is not automatically unacceptable, but unexplained complexity is difficult to underwrite.
Build three linked views
The legal view starts with the applicant and traces direct and indirect ownership to natural persons, showing percentages, voting rights, jurisdiction, registration number and source date. The control view identifies directors, authorised signatories, vetoes, shareholder agreements and anyone exercising control by other means.
The operating view follows a normal transaction: customer contract, invoice, payment rail, account, supplier or payroll outflow, tax/VAT treatment and retained profit. The same entity names, amounts, countries and roles must appear across all three views.
- One-page group chart with version date
- One paragraph on the purpose of each entity
- Directors, signatories and approval thresholds
- Expected monthly volumes, currencies and counterparties
- Source of opening capital and ongoing revenue
Attach evidence in the order a reviewer uses it
Lead with a two-page cover memo, not a forty-file archive. Then provide official registry extracts, constitutional and share documents, director and UBO identification, licences where relevant, tax/VAT registrations, contracts or advanced drafts, invoices, statements and Source of Funds or Source of Wealth evidence appropriate to the case.
Name files consistently and include translations where the provider requires them. Mark drafts, expired documents and pending changes. If a nominee, trust, foundation or layered holding exists, describe the legal and commercial reason and provide the instruments that establish control. A public register is an important source, but FATF guidance supports a multi-source approach rather than treating one register as conclusive.
Repair contradictions before submission
Typical failures are a website that describes another activity, dormant filings alongside high forecasts, a director who cannot explain the business, ownership percentages that do not reconcile, accounts in unrelated countries, or projected flows with no contract path. Fix the underlying record where it is wrong; do not conceal the mismatch in a memo.
The structure pack is a controlled document. Update it after a share transfer, new director, bank, material client, market, licence or payment route. This framework does not guarantee acceptance and does not replace jurisdiction-specific legal or tax advice.
Questions clients ask
Is a beneficial-ownership chart enough for KYB?
No. It helps identify ownership, but the bank also needs control, purpose, activity, expected transactions and supporting evidence.
Should every holding company be removed before applying?
Not automatically. A holding entity may have a valid purpose. The question is whether its role, control, records and cash flows are lawful, current and explainable.
How often should the pack be updated?
At every material change and before each onboarding or review. Put a version date and owner on the pack so the bank can see which facts are current.