Changes in the structure

When the ownership of an accepted client changes (shares change hands, a new investor joins, a UBO leaves) or the board changes, the file must be updated and the change re-assessed. A change in ultimate beneficial ownership is a new acceptance decision, and runs through the same steps as the original onboarding.

First, record the new structure

Open the client’s onboarding form from the dashboard, press Edit information and go to the Structure section:

• Adjust the shareholdings, add the new shareholders or directors, and remove the parties that left the structure.
• Removing a node asks you what you mean: removing the node leaves the party active under the client, while archiving the party moves it to the archive, from where it can be linked to another node later.
• Your client can also make the change themselves through the portal, if they have the update permission.

Every new person or company in the structure becomes a party, exactly as during onboarding: invite each new natural person to complete their own form, and collect the corporate documents for companies. This works the same as Step 3: Shareholders & other parties.

Check the old situation first

The Organization history button on the client’s UBO tab shows the chart over time. Selecting an entry renders the structure as it was then, highlighting which parties were added and which were removed. Changed percentages are not highlighted, so compare those by eye. Use it to document what actually changed.

Then run the change through the acceptance steps

1. Collect the information: the new parties fill in and sign their forms, or you fill them in on their behalf. The client’s status moves back through Pending information as they do.

2. Verify every new and changed party with the verification wizard, so their Information verified flag is set.

   Existing parties whose situation genuinely did not change keep their verification. Parties whose form you unlocked to correct something lose it automatically and have to be verified again.

3. Screen the new persons and companies, and re-screen the client company, once the client is back at Pending compliance.

4. Update the risk profile: compliance sets the final risk classification again and answers whether the MLCO agrees, and management confirms whether the client is still approved.

Because the client status is derived from its parties, adding a new unverified party automatically pulls the client back out of Accepted until that party has been verified and the risk profile has been confirmed again. The client list therefore always shows which accepted clients currently have something outstanding.

Directors only

A change in directors without a shift in ownership follows the same route, but is usually much lighter: the new director fills in their personal form, you verify them, screen them and confirm the risk profile. Directors never carry an ownership percentage, so the rest of the structure is untouched.

Record what changed

The mechanics above update the file, but not the reasoning. Write down in the client’s internal notes what changed, when, and on the basis of which documents (a deed of transfer, an updated shareholders register). Together with the Audit trail, which records every status change automatically, and the organization history, that gives you a complete account of how the structure evolved.