Two laws – two almost identical sets of criteria
Last updated: 20 January 2026.
The criteria are different in the Act on Register of Beneficial Owners and the Anti-Money Laundering Act when it comes to whether a person is considered as a beneficial owner.
| The Beneficial Owners Act | The Anti-Money Laundering Act |
|---|---|
| 1. A risk-based approach is not relevant because the identification of beneficial owners is objective. | 1. A risk-based approach must be assessed and may lead to the identification of a beneficial owner. |
| 2. Close family members' ownership and control are not automatically aggregated. Several owners can, however, agree to a collaboration which in total surpasses 25.01 percent. This also includes agreements in the statutes, memorandum of association, shareholders' agreements, or other internal agreements. | 2. Ownership of close family members and control are to be aggregated. |
| 3. By indirect ownership through intermediate organisations, the beneficial owner in organisation C must control 50 percent or more in organisation B, which in turn controls 25.01 percent or more in organisation A. | 3. By indirect control through intermediate organisations, a beneficial owner in organisation C must control 25.01 percent or more in organisation B, which in turn controls 25.01 percent or more in organisation A. |
| 4. Politically exposed individuals are not to be registered. | 4. Politically exposed individuals and their closely related must be identified. |
| 5. The subsidiaries of listed companies must identify their beneficial owners. | 5. Majority owned subsidiaries of listed companies are exempt from the obligation to identify their beneficial owners. |