Control over a company is not always visible at the first layer. A counterparty report maps who holds that control, through which structure, and to what depth — before a transaction closes. The tier determines how far that mapping goes.
Each tier answers a defined set of questions from official sources. The ceiling of what the sources allow is stated before payment, not after.
What the report establishesControl structure, registered directors, and shareholder of record — drawn from official corporate registries. Scope varies by tier and jurisdiction. Source typeOfficial corporate registries, filed financial statements, and insolvency registers. No tier draws on unverified third-party databases. Price tiersThree fixed tiers: Signal, Standard, Extended. Price tiers are not published for this page; scope is defined below. Ceiling of knowledgeStated per jurisdiction before engagement. Where a registry does not disclose beneficial ownership, the report names the layer at which the chain stops and the reason.What a counterparty report covers
A counterparty report answers one question: who controls this entity, and what can a shareholder enforce against that control?
The answer is built from three layers of official data.
Layer 1 — Registry of record. The corporate registry of the jurisdiction of incorporation. This layer shows the legal name, registration number, registered address, directors of record, and — where the registry discloses them — shareholders and their proportional interests.
Layer 2 — Filed documents. Annual returns, shareholder lists, and constitutional documents filed with the registry. These are not always current: filing deadlines vary, and a registry may hold documents that are months or years old.
Layer 3 — Insolvency and enforcement registers. Proceedings filed against the entity, judgments registered against directors, and any administrator or liquidator appointments on record.
The tier determines how many layers are covered, how many jurisdictions are searched, and whether the report includes a structured analysis of what the sources do and do not show.
The three tiers: Signal, Standard, Extended
Signal
Signal covers Layer 1 in the jurisdiction of incorporation. It returns the registry extract: legal name, registration number, registered address, directors of record, and — where the registry discloses them — shareholders of record with proportional interests.
Signal does not include filed documents, insolvency searches, or any analysis of the ownership chain beyond the first registered layer.
Signal is appropriate when the question is narrow: does this entity exist, is it in good standing, and who is named as director?
Standard
Standard covers all three layers in the jurisdiction of incorporation. It includes the registry extract, filed annual returns and shareholder lists for the most recent available period, and a search of the insolvency register.
Standard also includes a structured note on what the sources do not show: where the ownership chain stops, whether the registry discloses beneficial ownership, and whether filed documents are current or delayed.
Standard is appropriate when the question extends to the financial position of the entity and whether any enforcement action is on record.
Extended
Extended covers all three layers across multiple jurisdictions. Where the registered shareholder is itself a legal entity, the search extends to that entity's jurisdiction of incorporation and repeats the Layer 1 and Layer 2 searches there.
Extended includes a structured analysis of the full ownership chain to the depth the sources allow, a note on each layer where the chain stops and why, and a comparison of what different registries show for the same entity or group.
Extended is appropriate when the counterparty is held through an intermediate holding structure, or when the transaction involves entities in more than one jurisdiction.
What is included at each tier
| Element | Signal | Standard | Extended |
|---|---|---|---|
| Registry extract (name, number, address, directors) | ✓ | ✓ | ✓ |
| Shareholders of record with proportional interests | Where registry discloses | Where registry discloses | Where registry discloses, across all searched jurisdictions |
| Filed annual returns and shareholder lists | — | Most recent available period | Most recent available period, all searched jurisdictions |
| Insolvency register search | — | ✓ | ✓ |
| Ownership chain analysis | — | First registered layer | To depth sources allow, across jurisdictions |
| Note on what sources do not show | — | ✓ | ✓ |
| Multi-jurisdiction coverage | Single jurisdiction | Single jurisdiction | Intermediate holding entities included |
| Structured comparison across registries | — | — | ✓ |
The limit of what the sources allow
Official registries do not show the same information in every jurisdiction. The following limits apply across the 35 jurisdictions covered.
Beneficial ownership. Following the Court of Justice of the European Union ruling in joined cases C-37/20 and C-601/20, public access to beneficial ownership registers in EU member states is no longer available as a default. Where a national register has implemented a restricted access regime, access requires a demonstrated legitimate interest. The report states, for each jurisdiction, whether the beneficial ownership register was accessible at the time of extraction and what condition of access applied.
Shareholders of record. Some jurisdictions do not require the corporate registry to publish a shareholder list. In those jurisdictions — including several common-law offshore structures — the registry extract shows directors only. The report names this limit explicitly.
Filed documents. Filing deadlines vary. A registry may hold a shareholder list that is one or more years old. The report states the filing date of each document used, not only the extraction date.
Insolvency. A negative result in an insolvency register does not confirm that no proceeding has been filed. Some registers update with a delay. The report states the register searched, the date of the search, and any known delay in that register's update cycle.
Intermediate holding entities. Where a shareholder of record is itself a legal entity, the chain continues into that entity's jurisdiction. Extended tier covers this. Signal and Standard do not follow the chain beyond the first registered layer.
The ceiling of what the sources allow is stated before payment. Where a source does not disclose a fact, the report names the source, the limit, and the reason — not a gap in the document.
Where the sources disagree
Discrepancies between sources are reported as findings, not resolved by the analyst.
The most common discrepancy in counterparty reports is between the shareholder list filed with the corporate registry and the shareholder list disclosed in the annual financial statements. These are filed at different times, under different obligations, and may reflect different moments in the ownership structure.
A second common discrepancy is between the registered address and the address shown in filed documents. This is noted in the report without interpretation.
Where the insolvency register shows a proceeding that does not appear in the registry extract — or vice versa — both records are reproduced and the discrepancy is stated.
FAQ
Does Signal cover beneficial ownership? Signal covers what the corporate registry of the jurisdiction of incorporation discloses. Where that registry publishes a beneficial ownership register and access is available, Signal includes it. Where access requires a demonstrated legitimate interest or is restricted by national implementation of post-CJEU rules, Signal states the limit and does not include beneficial ownership data.
What does Standard add over Signal? Standard adds filed documents — annual returns and shareholder lists for the most recent available filing period — and a search of the insolvency register. It also includes a structured note on what the sources do not show, including where the ownership chain stops and why.
Can Extended follow a chain through more than two jurisdictions? Extended follows the chain to the depth the sources allow. Where an intermediate holding entity is itself held through a further entity in a third jurisdiction, the search extends there. The report states at each layer whether the search was completed and what the source returned.
What if a registry is not publicly accessible? Where a registry requires registration, a national identifier, or a declaration of legitimate interest, the report states this condition and whether it was met. Where the condition could not be met for a foreign applicant, the report states the limit. No tier guarantees access to every registry in every jurisdiction.
Is the report a legal opinion? No. The report is a factual compilation from official registers and public sources. It does not contain a legal qualification of the facts established. For advice on what the established facts mean for a specific transaction or position, contact VLO Law Firm directly.
How current is the data? Each document and registry extract carries the date of extraction. The report does not represent that the data is current beyond that date. Filing delays in the source registry are noted where known.
Sources
Official corporate registries, insolvency registers, and filed financial statements across 35 jurisdictions. Specific registry names and URLs are provided in each delivered report, keyed to the jurisdiction and document type. No third-party aggregator databases are used as primary sources.
Registry source verification dates are stated in the delivered report. All extractions for reports issued under this page are on or before the publication date of this page.
Request this report
Disclaimer: This report is a factual compilation from official registers and public sources. It is provided for informational purposes only, does not constitute legal advice, and contains no legal qualification of the facts established. VLO Law Firm assumes no liability for actions taken or not taken based on this material. For advice regarding your particular situation, please contact info@vlolawfirm.com.
Author: Elena Moretti — Partner, Continental Europe, VLO Law Firm
