Two laws – two almost identical sets of criteria
Last updated: 7 October 2025.
The criteria are different in the Act on Register of Beneficial Owners and the Money Laundering Act when it comes to whether a person is considered as a beneficial owner.
| The Beneficial Owners Act | The Money Laundering Act |
|---|---|
| 1. Risk-based approach is not relevant because identification of beneficial owners is objective. | 1. A risk-based approach should be assessed and may lead to be considered a beneficial owner. |
| 2. Close family members' ownership and control are not automatically aggregated. Several owners can, however, agree to collaboration exceeding 25.01 percent. This also includes agreements in statutes, memorandum of association, shareholder agreements, or other internal agreements. | 2. Ownership of close family members and control are to be aggregated. |
| 3. By indirect control through intermediate businesses, a beneficial owner in business C must control 50 percent or more in business B, which in turn controls 25.01 percent or more in business A. | 3. By indirect control through intermediate businesses, a beneficial owner in business C must control 25.01 percent or more in business B, which in turn controls 25.01 percent or more in business A. |
| 4. Politically exposed individuals are not to be registered. | 4. Politically exposed individuals and their closely related must be identified. |
| 5. Subsidiaries of listed businesses must identify their beneficial owners. | 5. Majority owned subsidiaries of listed businesses are exempt from the requirement to identify their beneficial owners. |