A client sends you a certificate of incorporation, a share register naming one corporate shareholder abroad, and a director that is itself a company. Nothing on the page is a natural person. The question is how far the Law makes you walk that.
In Cyprus the answer is in the statute, not in a supervisor's directive. Section 2 of L.188(I)/2007 defines the beneficial owner as the natural person who has the ultimate possession or control of the customer and/or the natural person on whose behalf a transaction or activity is carried out, and says the term includes at least the persons then listed. At least. The list is a floor.
For a legal person, subparagraph (i) is the natural person holding the ultimate ownership status or ultimate control, directly or indirectly, in a sufficient percentage of the shares or the voting rights or the ownership right, among others through bearer shares or through control by other means. Two provisos then supply the arithmetic. Direct ownership is indicated by 25% plus one share, or an ownership right of more than 25%, held by a natural person. Indirect ownership is indicated by the same holding held by a legal person under the control of a natural person or persons, or by several legal persons under the control of the same natural person or persons. Both are indications.
Control by other means may be ascertained, among others, on the basis of the criteria in section 142(1)(b) and section 148 of the Companies Law. FATF's 2026 methodology sets a similar cascade for assessors: a controlling ownership interest, then control through other means where there is doubt or where no natural person exerts control through ownership interests, then the senior managing official where neither of those identifies anyone.
Both escapes carry conditions, and the conditions are the point. A listed company is outside subparagraph (i) only where it is subject to disclosure requirements under EU legislation or to equivalent international standards ensuring adequate transparency about the beneficial owner. The senior managing official applies only after all possible means are exhausted and provided there are no grounds for suspicion. FATF's glossary says that provision does not amend or supersede the definition of who the beneficial owner is; it only sets out how CDD should be conducted where the beneficial owner cannot be identified.
For trusts, section 2(b) names the settlor, the trustee, the protector if there is one, the beneficiary or the class of persons in whose interest the arrangement is mainly established or operates, and any other natural person exercising ultimate control through direct or indirect ownership or by other means. Section 61C requires a trustee of an express trust administered in the Republic to obtain and maintain those same identifications.
The registers assist and do not conclude. A company established in the Republic obtains and keeps adequate, accurate and up-to-date information on its own beneficial owners and gives it to obliged entities doing CDD. Section 61A then forbids exclusive reliance on the Register and says the requirements are met using a risk-based approach, and you report any difference you find between the Register and what you hold. FATF's 2006 corporate-vehicles study found that in nearly all cases the information in a company registry relates to legal ownership, and not necessarily the beneficial ownership.
Section 61(1)(b) asks for reasonable measures, not all measures; section 61(2) lets you scale them to risk while requiring you to show your supervisor the extent is proportionate. Reasonable is not thin. It is documented.
Not legal advice. Verify against the primary source before acting.
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