Ownership Structure Chart for Bank and EMI Onboarding: What to Include and How to Document It

An ownership structure chart should make one thing easy: tracing the applicant company through its direct and indirect owners to the people who ultimately own or control it. A company ownership chart used for onboarding should make that chain readable before the reviewer opens the supporting records.

For a simple company, that may take only a few boxes. For a layered structure, the chart needs to show each intermediate entity and the relationship between one level and the next. The goal is not to reproduce the corporate records. It is to give the reviewer a readable map that can then be checked against those records.[1][2]

A useful way to think about it is:

For the broader onboarding file, see OnboardOS's Corporate Bank Account Opening Documents Checklist.

Ownership chart and organization chart are not the same document

Banks and EMIs do not always use the same name for the document. In practice, a request may refer to an Ownership Chart, Shareholding Structure Chart or even an Organization Chart while the reviewer is actually asking to see who owns the company.

That should not be confused with a traditional organizational chart.

An organizational chart shows the internal management hierarchy:

CEO → CFO → Finance team

An ownership chart shows the shareholding and UBO chain:

UBO → Holding Company → Applicant Company

For onboarding, the substance of the request matters more than the label. If the reviewer wants to understand ownership, the chart should show the ownership chain rather than the management structure.

If a corporate shareholder appears, the chart should continue through it until the relevant natural-person UBOs are shown.

Show the full ownership chain

If the applicant is owned by another company, the chart should not stop there.

The chain should continue through intermediate shareholders until it reaches the natural persons who ultimately own or control the structure.[1][2] The direct shareholder can be only one layer in a much larger ownership story.

In practice, this is a common point of confusion. A client may show that Company A owns the applicant and treat the chart as complete. It is not complete if Company A is itself owned by another entity or individual. The chart needs to continue through Company A and any further corporate shareholders until the relevant UBOs are visible.

In a more layered structure, each branch should remain traceable separately. If one branch ends at a corporate entity with no explanation of who sits behind it, the reviewer is still missing part of the ownership picture.

Some financial institutions make this expectation explicit. HSBC asks for each Intermediate Owner up to the Beneficial Owners to be shown, while Airwallex asks for the full pathway to ultimate ownership where beneficial owners hold shares through intermediate entities.[4][5]

Make each ownership relationship readable

A chart is useful only if the connections are clear.

For a company block, a practical minimum is usually the legal company name, jurisdiction and company number. For an individual UBO, the chart normally needs far less: the person's name and the ownership percentage are often enough to understand the relationship.

Provider requirements follow the same general pattern. HSBC asks for company names, ownership or voting percentages and countries of incorporation for intermediate owners; BNP Paribas asks for ownership percentages at each intermediary layer, full registered names and countries of incorporation.[5][6]

Put the percentage on the relationship it describes. If Company A owns 80% of Company B, the 80% should sit on that connection rather than somewhere else on the page.

Do not turn each box into a mini KYC file. The purpose of the chart is to explain the structure, not to display everything known about the company or UBO.

Ownership and control are not always the same

Ownership percentage is important, but it does not always identify everyone who ultimately controls a company.

FATF guidance treats beneficial ownership as a question of ultimate ownership or control and notes that a threshold is one way to identify ownership interests, while the FATF Recommendations do not prescribe one universal percentage threshold.[1] AUSTRAC similarly distinguishes ownership from control and describes control that can arise through voting rights or other means.[2]

That is why a chart should not automatically treat shareholding percentage as the whole UBO analysis. In a layered structure, the same document may also function as a beneficial ownership structure chart, because it shows how the ownership chain reaches the relevant natural-person UBOs.

If one person has an economic interest while another person has effective control, the chart or an accompanying note should make that distinction understandable.

This is also why a statement such as “a UBO is anyone who owns 25% or more” is too broad for a general onboarding guide. Individual financial institutions may use a 25% threshold in particular onboarding contexts, but the applicable test depends on the provider and jurisdiction.[1][4][7]

Connect the chart to supporting evidence

The chart explains the structure. The underlying records substantiate it.

A useful practical rule is to ask what proves each arrow on the chart.

If the chart says Company A owns 75% of Company B, there should be a record that supports that relationship. In real onboarding files, this may be a registry extract, Certificate of Incumbency, Shareholders Register or another reliable corporate record. The appropriate document depends on the entity and jurisdiction.[3][6]

The same logic applies at every corporate layer. If Company A is itself owned by Company C, the evidence should support that next arrow as well, allowing the chain to continue until the relevant UBOs or controlling persons can be identified.

This is where an ownership chart becomes more than a diagram. It gives the reviewer a structured view of the ownership story, while the supporting records provide the basis for checking it.

Check the chart against the rest of the onboarding file

A clear chart can still create problems if it tells a different story from the rest of the submission.

In practice, the most ordinary mistakes are often enough to trigger questions: a person's name is written differently, a company name is wrong, or an ownership percentage does not match the supporting document or onboarding form.

Before sending the chart, compare the legal names, company details, ownership percentages and UBO information with the corporate records and the information entered in the bank or EMI application.

An outdated Shareholders Register can create the same problem if it reflects a previous ownership split while the chart shows the current one.

The goal is not cosmetic consistency. It is to avoid making the reviewer decide which version of the ownership structure is current.

Keep complex structures explainable

The more complex the ownership structure, the easier the chart should be to read.

Once a structure moves beyond a simple owner-to-company relationship, clarity becomes more important. Several holding companies, different ownership branches or multiple jurisdictions can be perfectly representable, but the reviewer still needs to follow each path without decoding a page of crossing arrows.

Use separate branches, keep labels short and remove information that does not help explain ownership. More detail does not automatically make the chart more useful.

Nominee ownership deserves particular attention. In practical onboarding work, a nominee arrangement commonly prompts a request to explain why it exists and who ultimately owns or controls the interest behind it. The chart should therefore make the underlying relationship visible and the accompanying explanation should deal with the reason for the arrangement where requested.

Complexity can also matter from a CDD perspective. FATF and AUSTRAC guidance both focus on identifying the natural persons who ultimately own or control legal persons, which means layered structures still need to be traced to their endpoint.[1][2]

The goal is simple: the chart should reduce the reviewer's work, not make the reviewer solve the structure.

Ownership structure chart example: what a usable chart looks like

A practical ownership chart should let a reviewer find the applicant, follow each ownership branch and reach the relevant UBOs or controlling persons without rebuilding the structure manually.

A layered ownership structure may look like this:

For the company blocks, the final visual can show the legal name, jurisdiction and company number. For the individual blocks, the name and ownership percentage are usually enough for the chart itself. Supporting KYC information belongs elsewhere in the onboarding file.

Official examples are useful references. HSBC publishes an ownership structure chart sample showing intermediate owners, beneficial owners, percentages and jurisdictions.[5] HMRC publishes practical group structure examples showing how entities, countries and ownership percentages can be represented clearly, although those examples are designed for tax information rather than bank onboarding.[8] Wise's Singapore onboarding guidance includes a shareholder structure chart as part of its Beneficial Owner declaration process.[7]

These examples are references, not universal templates. The format and certification requirements can differ by provider.

Before the chart goes into the submission package

Before submission, check that:

The date and signature are easy details to miss. In practical onboarding work, charts are often expected to be dated and signed by an appropriate person such as a director or UBO, with the signatory's position stated. This should still be checked against the particular provider's request rather than treated as a universal rule.

Provider-specific requirements can differ materially. HSBC asks for its ownership structure chart to be certified by a director in the cited Hong Kong onboarding materials.[5] Airwallex's US guidance asks for its Attestation of Beneficial Ownership to be on company letterhead, signed by a director and dated within six months.[4] BNP Paribas Real Estate's KYC checklist contains its own certification requirements.[6]

The final test is simple: a reviewer should be able to understand the ownership structure from the chart and then verify the same story against the documents in the file.

About the author

Alexander Blinov is the founder of OnboardOS. His background includes corporate legal, KYC/AML and bank and EMI onboarding work for international companies. He is building OnboardOS to help corporate service providers collect client information, identify missing evidence and prepare consistent account-opening packages.

This guide provides general information for corporate onboarding preparation. It is not legal advice and does not represent the requirements of every bank, EMI, payment provider or jurisdiction. Requirements and risk appetites vary by provider and business model.