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A business entity lists the people who own and control it. Each of those people is an individual entity, linked to the business by entity_id in beneficial_owners[] and control_persons[]. See Linked entities. This page covers who to list, at what ownership threshold, and how to handle ownership through other companies. Sole proprietorships do not list beneficial owners or control persons. Set sole_proprietor to the individual behind the business instead.

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Requirements

Lead requires beneficial ownership information in line with the Customer Identification Program (CIP) reviewed during due diligence. At a minimum, list every natural person who owns 25% or more of the business, directly or indirectly, in beneficial_owners[].
  • Control person: list at least one natural person with significant responsibility to control, manage, or direct the business, like a CEO, COO, or president, in control_persons[] with a title. A control person is required regardless of ownership percentage.
  • Lower thresholds: if your Know Your Business (KYB) process states a threshold lower than 25%, list every beneficial owner who meets your threshold.
If no natural person meets the threshold, send an empty beneficial_owners array. The business still needs a control person. Every linked beneficial owner and control person must be eligible for authorized_signer, even if they will never sign. If one is not, the business is ineligible for account_holder, and its failed_checks point at that individual’s entity_id. See Failures on a linked entity.

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The drill-down rule

A beneficial owner must be a natural person. If another company, like a parent or holding company, owns 25% or more of the business, do not link that company as a beneficial owner. Apply the same 25% test to that company’s owners instead. Continue up the chain until you have found every natural person with a 25% or greater indirect stake in the original business.
  • Business: Bob’s Pizza Company
  • Owners: Alan (individual, 60%) and Bob (individual, 40%, also CEO)
  • Other individual: Charlie, an authorized signer on the user account
  • Action:
    1. Create individual entities for Alan, Bob, and Charlie that meet the authorized_signer data requirements.
    2. Create the business entity for Bob’s Pizza Company. List Alan and Bob in beneficial_owners[], since each owns 25% or more. List Bob in control_persons[] too, with the title CEO.
    3. Do not link Charlie to the business. Charlie is neither an owner nor a control person. Add Charlie to the user account as an authorized signer instead.
  • Business: SaaS Co
  • Direct owners: Parent Corp (company, 80%) and Jane Smith (individual, 20%)
  • Parent Corp is a company that owns 25% or more, so drill down. Parent Corp’s owners: Holding LLC (company, 50%) and Mark Lee (individual, 50%)
  • Holding LLC is a company, so drill down again. Holding LLC’s owner: Susan Kay (individual, 100%)
  • Each person’s stake in SaaS Co:
    • Jane Smith: 20% direct. Not a beneficial owner.
    • Mark Lee: 50% of 80% = 40% indirect. Is a beneficial owner.
    • Susan Kay: 100% of 50% of 80% = 40% indirect. Is a beneficial owner.
  • Action: create individual entities for Mark Lee and Susan Kay that meet the authorized_signer data requirements, and list both in beneficial_owners[]. Do not create or link entities for Parent Corp or Holding LLC. Also create an individual entity for SaaS Co’s control person, like its CEO, and list that person in control_persons[]. The control person may or may not be one of the beneficial owners.
Entity Overview · The Entity Object · Entity Eligibility