Five ownership layers. One question: who actually owns this account?

Visualise a synthetic corporate ownership chain as a layered network graph. Adjust the disclosure threshold to see who becomes a reportable ultimate beneficial owner (UBO) under FinCEN's Corporate Transparency Act, EU 6AMLD, the UK Persons-with-Significant-Control regime, and MAS. The graph flags sanctioned-proximity hops and circular ownership in real time. Exports the mandate the runtime enforces on every onboarding action.

Zero PII · Client-side · Synthetic graph Click a node to highlight its chain Last Reviewed · 2026-05-13

CTA · 6AMLD · UK PSC · MAS — convergence on 25% with caveats

FinCEN's Corporate Transparency Act (31 USC §5336, BOI rule effective 1 Jan 2024) requires reporting of beneficial owners at the 25% ownership / substantial-control threshold — current status: injunction-affected for domestic entities (March 2025 interim rule narrowed scope to foreign reporting companies). The EU 6AMLD (Dir. 2018/1673) sets a 25% baseline with member-state discretion to go lower; AMLA (Reg. 2024/1620) harmonises supervision from 2028. UK PSC regime (Companies Act 2006 Part 21A) requires Persons of Significant Control disclosure at 25%+. MAS aligns at 25% across PSN02 and the Companies Act. Notes: controllers via voting rights or trust arrangements can fall below the percentage but still be reportable.

Sources: 31 USC §5336 + FinCEN BOI Rule 2022; FinCEN Interim Rule (March 2025) · EU 2018/1673 (6AMLD) · UK Companies Act 2006 Pt 21A · MAS PSN02 · FATF Recommendation 24

Value at risk · KYB enforcement

FinCEN CTA: $591/day civil + criminal up to $10K / 2 years · EU 6AMLD: personal liability for directors · NYDFS recent KYB consent orders: 6–8 figure

FinCEN's CTA penalty regime (31 USC §5336(h)) is $591 per day per violation (2024 inflation-adjusted) for civil enforcement, plus criminal exposure up to $10,000 and 2 years for willful failure. EU 6AMLD extends personal liability to named senior management. Recent enforcement — TD Bank 2024 ($3B globally, with significant KYB-tied components) and NYDFS bank settlements 2023–2025 consistently cite UBO-identification gaps as core programme defects. The mandate binds the chosen disclosure threshold so the runtime cannot silently relax it between examinations.

31 USC §5336(h) · 31 CFR 1010.380 · EU 2018/1673 Art. 7 · FinCEN inflation-adjusted civil penalty (2024) · TD Bank 2024 settlement · NYDFS Coinbase 2023

§1 · Ownership Graph — nodes · — edges

Corporate-ownership chain

Customer entity (centre, dark) at the bottom; intermediate holdings and trusts mid-chain; individuals at the top. Edges show ownership share. Gold rings = reportable UBO under the current threshold; red = sanctioned-proximity; purple-dashed = circular-ownership cycle.

Customer entity Entity / holding co. Natural person Nominee / trust Sanctioned-proximity UBO (reportable)

§2 · Scenarios Switch the synthetic graph

Test alternative structures

Three illustrative graphs — switch to see how the threshold and jurisdiction rules play out across different ownership patterns.

§3 · Disclosure Regime FinCEN CTA

Jurisdiction

Disclosure threshold (%) All four regimes default to 25% but member-state / state-level discretion can go lower.

25%

Sanctioned-proximity max hops Counterparty within N hops of an OFAC-listed entity in the ownership graph triggers refer.

§4 · Compliance Scorecard — / 100

UBOs & risk

UBOs reportable

—

at current threshold

Compliance

—

UBO disclosure list

AP2 v1.0 · valid · @ainumbers.co/kyb-ubo-v1

Compose with

Pair with #11 — AML TM Rule Builder (UBO identification feeds the customer-risk-rating input that TM rules read) or #15 — VASP Travel Rule (VASP-to-VASP transfers require beneficial-ownership data on the originator side). The mandate this demo emits is consumable by #27 — Agentic Mandate Sandbox via custom-schema paste.