I have been leading COREDO since 2016, and during that time hundreds of structures have gone through our projects: from European fintech startups and crypto platforms to Asian holdings with multi-level chains of owners. The more regulation becomes complex, the clearer one thing: beneficiary checks by banks and other financial organizations have long ceased to be a formal checkbox. It is a key element of risk management and access to the international financial infrastructure.
In this article I want to show how OSINT beneficiary checks work in practice, how banks view ultimate beneficial owners (UBO), and how an entrepreneur should arrange their structure and documents so as not to get stuck on compliance when opening an account, obtaining a license, or taking part in a deal.
Beneficiaries: the central point of risk
Today any bank, payment institution, crypto exchange or electronic money issuer builds AML/KYC processes around three questions:
- Who actually controls the business (identification of beneficial owners, UBO)?
- What is the source of funds and the value of assets?
- What reputational and sanctions risk do the owners and related persons carry?
Therefore:
- KYC and beneficiaries are complemented by a full Due Diligence of beneficiaries, including analysis of affiliations, ownership chains and reputation.
- Most European and Asian regulators explicitly require a risk‑based approach: the more complex the structure and the higher the industry risk (crypto, forex, payment services, gambling, high-risk e‑commerce), the deeper the review should be.
- Banks are moving from “a tick-box for the regulator” to a model where OSINT as a bank risk management tool is embedded into credit risk, sanctions screening and even pricing.
In practice this means: if your beneficiaries and structure raise questions, you not only take longer to open an account – you lose access to key markets, licenses and investors.
How banks verify beneficial owners
Understanding what the verification of beneficial owners by banks is really built on starts with the basics: who exactly is behind the client and what formal data about them exists in documents and registries. At the KYC/KYB and formal identification level banks first build the “skeleton” of the check: they collect the minimally necessary information, confirm identity and ownership structure, and then move on to a deeper risk assessment and actual control.
Basic KYC/KYB level: formal identification
At onboarding the bank addresses the following tasks:
- identification of the legal entity (KYB): articles of association, registry, ownership structure;
- identification of beneficial owners: who owns or controls ≥ a certain threshold (usually 25%, sometimes 10%);
- checking documents and sanctions lists (OFAC, EU, UN, etc.), PEP‑status, basic AML client screening.
At this stage the classic set is used:
- corporate registries as a source of data on beneficial owners;
- international company and beneficial-owner databases (commercial providers);
- sanctions and PEP databases, negative news (negative news screening).
But for international structures and complex cases that’s not enough.
When EDD is triggered: verification of beneficial owners
EDD (enhanced due diligence) for beneficial owners is triggered when:
- complex verification of the ownership chain (multiple layers, holdings in several jurisdictions, offshore links);
- high-risk industry (crypto, fintech, forex, payment services, gambling);
- presence of PEPs, sanctioned jurisdictions or countries with weakened AML supervision;
- there are already negative signals from the media, court rulings, or the industry.
At this level OSINT becomes a mandatory tool in AML/KYC processes.
What is OSINT in compliance, and why is it needed?
- forming hypotheses (who the real controlling persons are, where the risks lie);
- link analysis, analysis of connections and affiliations;
- preparing an analytical dossier on the beneficiary with a risk assessment.
In the COREDO team’s work I roughly divide OSINT into:
- passive OSINT – collecting information without interacting with the subject (registries, media, social networks, databases, website archives);
- active OSINT – requests to relevant organizations, checks through industry communities, correlating data using indirect indicators.
OSINT sources for verifying beneficiaries
Key OSINT sources for verifying beneficiaries not only allow confirming the officially declared ownership structure, but also reveal hidden links, nominee owners and chains of organizations. In practice, registries and corporate databases become the main support, providing initial legal and financial data for further in-depth analysis.
Registries and corporate databases
Here the “skeleton” of the client’s corporate structure review is created:
- national corporate registries as an OSINT source:
- OSINT sources for identifying UBOs in Europe: company registries, sometimes separate UBO registries;
- OSINT sources for beneficiary checks in Asia: in some countries data are partially available, requiring combining several registries and commercial databases;
- international databases for beneficiary checks help see connections between companies in different countries and assess the group’s structure;
- comparative analysis: public registries vs. commercial databases and OSINT sources – we often see discrepancies in dates, ownership shares, positions, and this becomes a trigger for EDD.
In practical COREDO projects, analysis of corporate registries often helps uncover hidden beneficiaries through related companies and nominee owners.
Court judgments and enforcement proceedings
This is a goldmine for EDD:
- court judgments as an OSINT source when assessing beneficiaries: disputes with regulators, creditors, tax authorities, partners;
- databases of enforcement proceedings and bankruptcies – long-term behavior patterns, attempts to evade responsibility;
- recovery cases and forensics: how owners behaved in crisis situations.
Media and social networks
This is where the picture of reputational risks is formed:
- news and industry media: using news and media resources to check beneficiaries, negative news screening, investigative materials;
- media monitoring and negative publications about beneficiaries: not only high-profile scandals, but also local conflicts, accusations, regulatory claims;
- social networks as an OSINT source on beneficiaries: confirmation of biography, connections, involvement in projects, and SOCMINT (social media intelligence) to assess affiliation and behavioral patterns.
How to identify hidden and nominal beneficiaries
Hidden beneficiaries and nominal owners: a topic that banks and financial institutions face constantly, especially in international holding structures.
Analysis of affiliations and related parties
Here OSINT operates at the intersection of:
- matching addresses, directors, phone numbers, e-mail domains;
- the participation of the same individuals in multiple entities (often in different countries);
- cross-references in media, court decisions, industry publications.
Advanced search and OSINT Framework
Practical tools:
- using advanced search (Google Dorks) when checking UBOs — searching old press releases, cached pages, presentations where beneficiaries were mentioned before the ‘optimization’ of the structure;
- using the OSINT Framework when checking beneficiaries, systematizing sources by type (registries, social networks, media, technical data);
- analysis of domain histories, WHOIS, old versions of sites via web archives.
OSINT in banking, EDD, and AML systems
OSINT in the bank’s EDD process and AML systems is turning from an auxiliary tool into one of the key sources of information about a client’s risks and their environment. Proper integration of OSINT into the bank’s AML processes allows strengthening EDD checks with data from open sources, supplementing the results of commercial databases and internal systems.
Integration of OSINT into the bank’s AML processes
The bank cannot afford “manual” OSINT at an industrial scale. Therefore important:
- integration of OSINT into the bank’s AML systems: connecting external sources via API, automatic negative news screening, alerts for sanction changes;
- OSINT tools for financial institutions: web-scraping systems, media monitoring, SOCMINT, platforms for link analysis;
- continuous monitoring: regular dossier updates and monitoring of key beneficial owners.
OSINT in risk scoring and fraud detection
In mature models, OSINT data is fed not into a separate report, but directly into risk scoring:
- assessment of clients’ creditworthiness using OSINT: taking into account legal disputes, histories of defaults, conflicts with counterparties;
- OSINT in the investigation of financial crimes and money laundering – forensics, reconstruction of transaction chains, identification of nominee owners;
- OSINT as a tool for bank risk management: early detection of problematic beneficial owners before defaults occur.
As a result, the bank better understands who it is working with, and can more precisely adjust limits, pricing and terms.
How to prepare an OSINT check of beneficiaries
When I discuss with clients opening an account or obtaining a license in the EU, the UK, in Cyprus, Estonia, Singapore or Dubai, I always say the same thing: you need to prepare not only the documents but also your digital footprint.
What makes sense to do in advance:
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Transparent structure
- minimize unnecessary intermediaries, especially in offshore jurisdictions without clear registries;
- provide documented explanations of the ownership-chain verification: why the structure is the way it is, where added value is created, and where management is located.
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Data consistency
- cross-check corporate registers, statutory documents, media profiles and the company’s website;
- avoid situations where in one place the beneficiary is “advisor”, and in another, “founder and 100% owner”.
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Reputational audit using OSINT
- conduct a preemptive check of beneficiaries’ reputational risks: media, court databases, professional communities;
- if necessary – prepare explanations for contentious cases (for example, a conflict with a former partner, or a legal dispute that has been closed).
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Documentary support
- prepare a package that meets not only formal requirements but also the logic of AML/EDD: business model, source of funds, key contracts;
- for international structures: logically connect all parts from a business and tax perspective.
OSINT, company registration and licensing
OSINT, company registration and Licensing: a practical perspective helps businesses not only understand who they are dealing with, but also foresee legal and reputational risks when working with foreign jurisdictions. By analyzing public registers, licenses and corporate links, it is possible to build a safer strategy for registering a company abroad, minimizing the likelihood of mistakes and regulator claims.
Company registration abroad and OSINT
When registering companies in the EU, the UK, in Cyprus, in Estonia or in Asian centers (Singapore, Dubai), checking the client’s corporate structure and beneficiaries has become a standard part of the process:
- registrars and banks use OSINT to vet counterparties and partners, especially when the structure is international;
- regulators expect licensees to be able to conduct OSINT during client compliance checks;
- when licensing (crypto, payment, forex, investment services) the decision often depends on how transparent the UBO appears from an OSINT perspective.
Crypto and fintech licensing
- OSINT‑approaches to checking beneficiaries in high‑risk sectors (crypto, gambling, forex) include in‑depth analysis of media, industry investigations and business connections;
- sanctions checks and beneficiaries in such projects are supplemented by assessment of indirect links (countries, counterparties, sources of capital);
- OSINT in cross‑border transactions and foreign‑economic deals is becoming a mandatory part of AML policy/CTF.
Strategic questions for the owner and top executive
If you manage a banking group, a fintech company, or a large corporate business, I would ask myself the following questions:
- How integrated is OSINT screening of beneficiaries into the standard onboarding process?
- Do we have a unified standard for an analytical dossier on a beneficiary and its regular updating?
- What portion of the work is automated (web-scraping, API, alerts), and what is performed manually and at risk of “getting lost”?
- Do I understand which mistakes banks most often make when using OSINT: excessive trust in commercial databases, ignoring local sources, weak documentation of conclusions?
- Are our clients and their beneficiaries prepared for such depth of screening, or does every EDD case turn into crisis management?
Why OSINT is about management, not apprehension
From an entrepreneur’s perspective, OSINT‑checks are often perceived as a barrier. In practice it is a tool for:
- anticipating regulatory and sanctions risks;
- protecting the business from toxic partners and counterparties;
- improving the quality of decisions in M&A transactions, lending, and investments.