Global business brings incredible opportunities, but it also comes with real risks. One of the trickiest is dealing with local laws that restrict public disclosure of ultimate beneficial ownership (UBO) information.

This creates a serious compliance headache. Without access to ownership details, you could end up doing business with entities involved in financial crime, corruption, or under international sanctions.

What can you do about it? Here are practical steps to manage this complexity while maintaining a strong, ethical compliance programme.

1. Adopt a Risk-Based Enhanced Due Diligence (EDD) Approach

The standard Know-Your-Customer (KYC) checks are insufficient here: from databases you will just receive the notification that “ownership information not available” or “restriction order”.  You need to apply Enhanced Due Diligence (EDD) whenever you’re dealing with high-risk situations.

Think in a risk-based way and focus your energy on the highest-risk partners. Which ones? Entities in jurisdictions with weak anti-money laundering (AML) controls. Places known for high corruption. Companies with unusually complicated ownership structures. These need extra scrutiny.

Key Actions in EDD:

• Focus on People, Not Just Entities

Don’t stop at checking the company name. You need to dig deeper. Identify key individuals behind the company such as directors, executives, and major shareholders. Even when ownership is hidden, people leave digital footprints. Look through professional networks, past business activities, and media mentions. Search engines are a great help to collect some more pieces of the puzzle.

• Deep Dive on Management

Vet the directors and senior management thoroughly. Do their professional backgrounds add up? Are they Politically Exposed Persons (PEPs)? Check for connections to PEPs as well.

• Analyse the Source of Funds and Wealth

Where did their money come from? Knowing the source matters. Request detailed financial records, contracts, and tax documents. They need to demonstrate that their assets and funds originated from legitimate business activities.

• Investigate Business Rationale

Does their transaction volume match their business? A small local company processing multi-million-dollar transfers is a red flag. You must investigate immediately.

• Address Complex Structures

Are they shell companies? Do they have multiple ownership layers? Demand a clear, documented breakdown from your potential partners. You need to trace back to the ultimate beneficial owners. There are no exceptions.

2. Leverage Independent Data Sources and Local Expertise

What do you do if official registers aren’t available? Then you need to get creative with your information gathering. Relying solely on what your partner provides isn’t enough for robust compliance.

Reliable Data Tools:

• Global Sanctions and Watchlists

Run names against sanctions lists. This is non-negotiable for compliance with international sanctions laws. The penalties for getting this wrong are massive.

• Adverse Media Screening

Search news archives, blogs, and public sources. Look for mentions of fraud, corruption, and lawsuits. You might find reputational risks that won’t show up in official records. It helps you identify problems before they become your problems.

• Litigation and Court Records

Past legal disputes tell you a lot. Financial troubles show up in the records too. This data is critical for assessing a partner’s reliability and identifying potential legal or financial issues down the line.

• Commercial Databases

Third-party providers aggregate data from thousands of international sources. They map complex corporate structures and ownership networks. These databases help you piece together beneficial ownership and understand cross-border relationships more completely.

Engage Local Expertise

If you’re operating internationally, consider hiring people who know the territory. Local compliance consultants or law firms bring invaluable insights into local business practices, ownership norms, and regulatory expectations. They can access information that would be impossible for an outsider to obtain.

3. Implement Clear Policies and Maintain Audit Trails

Here’s the most important long-term move. Define your company’s risk tolerance, or you could call it also “risk appetite”. Then build clear policies around it and explain it to your team. Make it crystal clear when you’ll walk away from a deal.

Policy Cornerstones

• “No-Go” Policy for Non-Cooperation

Is a potential partner dragging their feet on providing EDD documents? Are they outright refusing? If so, the relationship stops there. Make this rule non-negotiable. This is because legitimate businesses shouldn’t need to hide.

• Continuous Monitoring

Compliance isn’t a checkbox exercise. For all relationships in restricted jurisdictions, you must implement ongoing screening. This helps detect unusual activity, changes in corporate structure, or shifts in key personnel.

• Mandatory Documentation and Audit Trails

Make sure to document everything. This includes every action, every decision, and every piece of information you collected. Even document what you couldn’t obtain. This paper trail proves your due diligence efforts. You’ll need it if regulators come knocking.

Balancing Compliance and Business Needs

Dealing with ownership restrictions requires a delicate balance. You need to protect your company from legal, financial, and reputational risks. At the same time, you must respect local privacy regulations.

Transparency and proactive risk management are your friends here. Local law might not require a partner to disclose their ownership structure, but if they refuse to provide reasonable information, it is a red flag. Then it is time to reconsider the relationship.

The formula is straightforward. Focus on people, not just entities. Use independent experts and data sources. Keep meticulous records. That’s how companies maintain global growth while managing the real risks that come with hidden ownership.

How Can Trustnet.Trade Help

Trustnet.Trade helps you close critical sanctions compliance gaps by going far beyond basic name screening. With instant KYB and UBO checks, real-time monitoring, and global sanctions screening including AMS and PEP, Trustnet.Trade helps you identify indirect ownership risks. Its automated alerts, visual ownership mapping, and compliance widgets give you continuous monitoring and transparency. Combined with risk-based questionnaires, and whistleblower modules, it keeps companies of any size up to date with evolving regulations, preventing reputational and financial risks from escalating into significant problems.