Nikita Veremeev
11.12.2025 | 6 min read
Updated: 11.12.2025
Over the past two years COREDO’s clients have most often asked me the same question: “Is it possible today to build an international structure that is both efficient and still passes all beneficiary checks in Europe?”
Against the backdrop of the EU steadily tightening AML requirements and introducing new rules by 2025, this question becomes strategic rather than technical.
The European regulatory landscape is changing faster than many corporate structures can adapt: a single EU AML package, the creation of AMLA (the EU Anti-Money Laundering Authority), new criteria for determining the beneficial owner, digital registers, and tougher sanctions screening. These processes directly affect the registration of legal entities in the EU, access to bank accounts, and the ability to work with counterparties from Asia and the CIS countries.
In this article I will break down what the new EU beneficiary requirements mean for businesses in Europe, Asia and the CIS, how the 2025 AML directives are changing, and — most importantly — which practical steps to build into your strategy now. If you are planning expansion, restructuring your corporate structure or obtaining financial licenses in the EU, I recommend reading to the end: this is not theory but a distillation of what the COREDO team deals with every day in real projects.
New requirements for beneficiaries in the EU in 2025
By 2025 the EU is moving from fragmented directives to a coherent regulatory architecture:
a single AML/CFT regulation, an updated EU Anti-Money Laundering Directive (AMLD) and the supranational regulator AMLA strengthen control over who really stands behind companies and transactions.
Key areas of change:
- Expansion of criteria for determining beneficiaries in Europe 2025
The traditional 25% ownership threshold remains, but is no longer sufficient. Regulators increasingly use the concept of “criteria of substantial control”: the right to appoint and remove directors, control over key contracts, veto over strategic decisions, existence of trust and shareholder agreements. Formal splitting of shares no longer works: controlling influence matters more than the percentage of shares. - Mandatory and more frequent updating of beneficiary data in the EU
A strict obligation to update beneficiary information upon any material change in the structure is being introduced, rather than “once a year for form’s sake”. Many EU jurisdictions are already moving to a regime where delays in updating data in digital beneficiary registers are treated as an AML breach, not a corporate formality. - Digital beneficiary register and unified transparency standards
EU countries are moving toward unifying data formats and closer integration of registers. Information exchange between registers, banks, licensing authorities and AMLA is expanding. This increases the transparency of ultimate beneficiaries but sharply reduces room for incorrect structures. - Strengthening KYC procedures in Europe and control of ultimate company owners
Banks, payment organizations, crypto providers, investment firms and even certain non-banking entities (for example, luxury goods traders) fall under stricter KYC (Know Your Customer) procedures. Checks are not limited to form: regulators expect an analytical approach to ownership chains, sources of funds and potential sanctions risks.
In practice this means: company registration, account opening, obtaining a crypto or payment license in the EU in 2025 start with a well-thought-out model for disclosing beneficiaries, not end with it.
Who is the ultimate beneficiary under the new EU standards?
Over years of working at COREDO I have become convinced: most compliance problems arise not from a desire to hide something, but from an incorrect answer to the basic question – *’who is our ultimate beneficiary?’*
Criteria of substantial control
In the new EU approach, how to determine the ultimate beneficiary in the EU:
- ownership share (usually ≥25%, but for high-risk sectors the threshold de facto decreases);
- direct or indirect control through holdings, trusts, agreements;
- the right to determine the company’s strategy, approve the budget, block transactions;
- the ability to appoint/remove directors, control shareholder voting.
If a person does not meet formal ownership thresholds but has substantial control, they will be considered a beneficial owner.
Corporate audit of ownership structure
In COREDO projects across the EU, Asia and the CIS we almost always start with a corporate audit of the ownership structure:
- we build a complete ownership diagram down to individuals;
- we analyze shareholder and option agreements, powers of attorney, side letters;
- we check trust and nominee structures;
- we compare the structure with local requirements for company beneficiaries in the specific EU jurisdiction.
This work is not a formality but a safeguard: a correctly identified beneficial owner reduces the risk of subsequent claims against directors and licensed companies.
# Responsibility of directors and controlling persons
Directors’ responsibility for non-compliance with beneficiary requirements is increasing. It’s not only about fines:
- personal liability for incomplete or false disclosure;
- risk of disqualification as a director in the EU;
- possible blocking of the company’s licenses or accounts;
- increased scrutiny of deals and transactions connected to ‘questionable’ structures.
In several cases clients came to COREDO only after banks had frozen accounts due to the disclosed beneficial owners not matching the actual control. Fixing the situation proved more expensive than an initially built transparent approach.
Digital beneficiary registers in AML compliance
A new stage is the digitalization of compliance processes and the move to fully electronic digital beneficiary registers in the EU.
# Open and closed registers
After Court of the EU decisions many countries have limited public access to the data. At the same time:
- access to the data is retained for regulators, financial institutions and authorized persons;
- businesses are still subject to requirements to disclose information in the register;
- in some jurisdictions part of the beneficiary information is available to journalists and NGOs upon legitimate interest.
For COREDO clients we model separately what volume of owner data will actually be visible in each specific EU country, and how this will affect reputational and sanctions risks.
Automation of data updates and integration with ERP
In 2025 a new topic emerges – automation of beneficiary data updates and integration of corporate systems with EU digital platforms:
- data on changes of shareholders and directors are immediately reflected in internal systems;
- information is automatically prepared for submission to digital registers;
- reduction of the human factor and the risk of forgetting mandatory updates.
The solutions that the COREDO team develops together with IT partners allow integrating AML processes with corporate ERP systems, including triggers to notify the legal department when structures change.
# The impact of digitization on ownership transparency
Digital platforms for submitting beneficiary data and IBAN verification and identification of account owners in EU banks mean that ownership transparency of companies ceases to be an option. Any discrepancy between registers, the bank and the licensing authority automatically attracts attention and can trigger transaction monitoring and reporting.
Registration of legal entities in the EU: new requirements and international business
A few years ago the registration of legal entities in the EU in many jurisdictions amounted to a formal package of documents. In 2025 the impact of the new AML requirements on the registration of legal entities in the EU is already evident:
- in some countries, without a preliminary analysis of beneficiaries the registration authority will refuse incorporation;
- banks refuse to open accounts until a thorough analysis of the structure and sources of funds;
- financial licenses (crypto, payment, forex) are issued only when a structured AML-compliance system in Europe is in place.
AML control in Asia, the CIS and Africa
Businesses that combine the EU with Asia and the CIS come under increased scrutiny:
- transactions with counterparties from certain countries require enhanced Due Diligence under AML;
- for companies conducting operations in Africa and Asia additional AML control requirements may apply to cross-border transactions;
- AML checks and challenges for companies from the CIS include a detailed analysis of sources of funds, ownership structure and EU sanctions lists.
COREDO’s practice shows: a pre-established risk-oriented approach to AML that takes into account the geography of counterparties reduces the number of requests from banks and regulators and speeds up licensing processes.
Impact of EU sanctions on beneficiaries and owners
Sanctions on EU beneficiaries are not an abstract risk but a factor that alters business structure:
- An individual being listed on EU sanctions lists can block the group’s accounts and assets;
- blocking sanctions against businesspeople may require urgent restructuring;
- in some cases changes in ownership structure in Europe, Asia and Africa are required to maintain operational activity.
The COREDO team regularly conducts corporate audits of ownership structure taking into account sanctions and reputational risks, calculating how the impact of EU sanctions on beneficiaries and companies affects financing and entry into new markets.
Risks and challenges of non-compliance with the new requirements
Refusing to ‘bother’ with the new rules leads to tangible consequences.
- Legal and financial risks
Penalties, account freezes, license revocation, refusal to register or renew permits. - Sanctions risks and their impact on business
Being drawn into the area of suspicion under sanctions: even without a formal violation, it leads to delays in any regulatory procedures. - Liability for non-compliance with AML requirements
Directors and controlling persons face personal liability, including criminal liability, if the regulator classifies violations as intentional.
COREDO’s experience shows: preventive compliance expenses are far lower than losses from account freezes or the forced winding down of operations in the EU.
New restrictions on cash payments and business processes
A separate area of change — restrictions on cash payments in the EU.
- A ban on cash payments over 10,000 euros is being introduced for most transactions, with member states able to set lower limits.
- For certain sectors (for example, luxury goods traders) control is tightened, and cash transactions are strictly linked to EU AML requirements.
- This affects the operating model of distributors, B2B sales and some niche industries accustomed to cash turnover.
For COREDO clients we revise the contractual framework, implement procedures to confirm the provenance of funds and restructure financial flows so that the new restrictions on cash payments over 10,000 euros do not block operational activity.
Best practices for AML compliance and risk management in 2025
Strong AML compliance in Europe in 2025: it’s no longer just a “paper” policy, but a combination of processes, technologies and a risk management culture.
Recommendations for business preparation
In COREDO projects across the EU, Asia and the CIS, the following approaches have proven effective:
- establish a clear policy on company ownership transparency and disclosure of beneficial owners;
- formalize a risk-based approach to AML: classification of clients and counterparties, countries, types of transactions;
- conduct a corporate audit of the ownership structure before registration or licensing, not after the regulator’s first request.
Due diligence methods and risk management
Effective due diligence in AML includes:
- checking ultimate owners and directors against sanctions and PEP lists;
- analysis of sources of funds and the business model;
- assessment of jurisdictional risks for counterparties from the CIS, Asia and Africa;
- documenting decisions: why the client/counterparty was accepted, under what restrictions.
This approach allows not only to comply with the new AML for business rules in Europe, but also to defend your position to banks and regulators with sound arguments.
New AML monitoring technologies: AI and blockchain
The technology area is rapidly developing:
- AI systems analyze transactions, identifying suspicious patterns;
- blockchain solutions help trace the provenance of digital assets and compliance with requirements for crypto service providers;
- automated platforms allow scaling AML procedures for international business without a proportional increase in the compliance headcount.
The COREDO team participates in implementing such solutions for clients in the EU, Singapore and Dubai, focusing not on “trendy technologies” but on the concrete impact of AML requirements on companies’ ROI.
Integrating AML and scaling in ERP
To prevent compliance from hindering growth, it’s important to integrate AML processes with corporate ERP systems:
- automatic KYC initiation when creating a new counterparty;
- triggers for checks when ownership structure changes;
- connection to digital platforms for submitting beneficiary data;
- a single database for scaling AML procedures for international business when entering new jurisdictions.
AML controls for companies with international operations
International groups must take into account not only European rules, but also the specifics of Asia and the CIS.
- AML control in cross-border operations
Differences in reporting standards, KYC and sanctions regimes require a flexible yet coherent policy. - The impact of new AML requirements on operations of companies with counterparties from the CIS and Asia
Any links with higher-risk jurisdictions automatically lead to enhanced due diligence. - Control of operations with Russian counterparties in the EU
Banks and regulators in Europe have strengthened filters and require detailed justification of the economic rationale and transaction structure.
In COREDO’s legal support projects for company registration in the EU, Asia and Africa, we build unified risk management standards in AML and compliance so that a single deal in a problematic jurisdiction does not jeopardize the operational activities of the entire group.
Preparing businesses for EU beneficial owner requirements
To prevent the new rules from taking the company by surprise, I recommend putting in place a systematic plan.
- Step-by-step update of ultimate owner data
- conduct an internal corporate audit of the ownership structure;
- identify all beneficial owners under the new substantial control criteria;
- harmonize disclosures across all jurisdictions where the company operates;
- establish a process for regularly updating data on EU beneficial owners.
- Organizing internal controls
- appoint persons responsible for reporting requirements on ultimate owners in the EU;
- implement a procedure requiring legal department approval for any changes to the structure;
- document procedures for interaction with registrars, banks and licensing authorities.
- Implementation and optimization of KYC and AML procedures
- update KYC questionnaires, taking into account changes in KYC procedures in Europe in 2025;
- adapt policies to the requirements of the AMLD and national regulators;
- take into account the widening scope of AML supervision, including non-bank entities.
- Training and accountability of directors and employees
- conduct training on the responsibilities of directors and controllers;
- develop practical guides for interacting with banks and regulators;
- establish internal standards of conduct for responding to compliance requests.
- Preparation for inspections and audits under the new AML standards
- conduct a trial internal audit simulating a regulatory inspection;
- remediate identified gaps in documentation and processes;
- prepare a package of evidence that the company complies with the new EU beneficial owner requirements and AML standards.
In practice, the COREDO team often combines this plan with preparing to register new companies, obtain licenses, or restructure groups: doing so helps reduce the cost of changes and deliver results to the business faster.
Conclusion: what is important for a manager now
The EU is moving toward a model in which transparency of ultimate beneficial owners, digital registers and strict AML compliance become a basic condition for access to financial infrastructure. For an entrepreneur and a chief financial officer this is less a legal problem than a strategic factor: if a structure does not comply with the new rules, it simply stops working.
The real choice today is not between “transparent” and “not”, but between chaotic and managed transparency. At COREDO we see that companies that proactively review their ownership structure, set up processes for updating beneficiary data and invest in AML technologies gain not only in reduced risks, but also in deal speed, access to financing and resilience to crises.
If you are planning to register or restructure a business in the EU, obtain financial licenses, or prepare for stricter AML checks, it makes sense to turn the new requirements into a clear project now with defined stages, a budget and an expected ROI. This is how we approach clients’ tasks at COREDO — as investments in long-term resilience and scaling of international business.