Parent Company Share Registry

What this document is

A parent company share registry is the ownership record for the company that owns or controls the business being onboarded. Where a business is not owned directly by individuals but is instead owned by another company, we need to look through that parent entity to understand who ultimately sits behind it.

Think of it this way. If Company A is applying to open an account, but Company A is owned by Company B, then the share registry for Company A only tells us that Company B is the owner. To understand who actually controls the assets and makes the decisions, we need to look at who owns Company B. The parent company share registry is the document that tells us that.

This process of looking through layers of corporate ownership is called beneficial ownership tracing, and it is a legal requirement for regulated financial institutions in the United States. The goal is always to identify the real human beings who ultimately own or control the entity, regardless of how many corporate layers sit between them and the account.

Why we ask for this

FinCEN regulations require that we identify and verify every individual who owns 25% or more of a legal entity, directly or indirectly. The word indirectly is the key part here. If an individual owns 50% of a parent company that in turn owns 100% of the entity being onboarded, that individual effectively owns 50% of the entity and must be identified and verified.

Without the parent company share registry, we have no way of seeing through the corporate layer and identifying those individuals. Submitting only the share registry for the entity being onboarded would give us an incomplete picture and would mean we could not meet our regulatory obligations.

This requirement applies wherever the entity being onboarded is owned by another company, regardless of whether that parent company is based in the United States or overseas.

What your document must show

The document you submit must clearly display all of the following:

Required information	Details
Full legal name of the parent company	The company that owns or controls the entity being onboarded.
Full legal name of each shareholder	Every person or entity that holds shares in the parent company.
Number and class of shares held	How many shares each shareholder holds and what type they are.
Ownership percentage	The percentage of the parent company that each shareholder holds.
Date last updated	When the registry was most recently reviewed or updated.

What happens if there are multiple layers

In some cases, the parent company is itself owned by another company, creating multiple layers of corporate ownership. Where this is the case, we may need share registries for each layer until we reach the level where real individuals appear as shareholders.

If your ownership structure has more than one corporate layer, contact our onboarding support team before submitting. We can map out exactly what we need to see based on your specific structure, which is usually quicker than working through it document by document.

Acceptable documents

Any of the following will be accepted for the parent company, provided they include all of the required information listed above:

Stock ledger or register of shareholders for the parent company
Cap table for the parent entity showing all shareholders and ownership percentages
Shareholder agreement for the parent company detailing the ownership structure
Stock certificate records for the parent company evidencing share ownership

Example document

Below is an example of an acceptable document. Use this as a reference when preparing your submission.

Example of a parent company share registry document

Need help with this document?

Corporate ownership structures can be complex, particularly for businesses with international parents or multiple holding layers. If you are unsure which documents to provide or how many layers we need to trace through, contact our onboarding support team before you start gathering documents. We can save you a lot of time by mapping out exactly what we need upfront.