The question is precise: does VLO Law Firm work with individuals — a named director, a beneficial owner, or a person who is both? The answer is yes, and the scope is defined before engagement begins.
The angle here is control. Who holds the decision-making authority in the company? Who can bind it contractually? Who receives the economic benefit? These are distinct questions, and official sources answer them differently. The work is to map each question to the source that can answer it, extract what that source shows, and state clearly where the chain stops.
What is establishedDirector identity, appointment date, and registered authority — from company registers. Beneficial owner identity — from UBO registers where access is available. Source: jurisdiction-specific company and beneficial ownership registers · verified 2026-10-13 Who can be the subjectAny named individual: a director, a shareholder, a declared beneficial owner, or a person appearing in multiple roles simultaneously. Condition of accessAccess conditions vary by jurisdiction and register. Some registers are public; others require a declared legitimate interest or national identifier. No register is accessed without a lawful basis. What the sources do not showInformal control, undisclosed nominees, and structures held through bearer instruments are outside the scope of official registers.A director is a person formally registered as an officer of a company. The register records the appointment, the scope of authority, and — in most jurisdictions — the date of any resignation or removal.
A beneficial owner is a person who ultimately owns or controls the company, regardless of whether their name appears on the share register. Disclosure requirements differ sharply across jurisdictions. In some, a threshold of 25% triggers mandatory registration. In others, no public UBO register exists.
A person can be both. A sole founder who also serves as managing director appears in at least two layers of the register. The report maps each layer separately and notes where the same individual appears in more than one capacity.
The subject does not need to be the client. The client is the party commissioning the report. The subject is the individual being verified. These are routinely different people.
Director layer. Company registers in most jurisdictions record the full name, date of appointment, and registered address of each director. Some registers include nationality and date of birth. The extract is a point-in-time snapshot: it shows who is registered on the date of retrieval, not who held the position at an earlier date unless historical filings are available.
Shareholder layer. Share registers or filed shareholder lists show who holds equity and in what proportion. In some jurisdictions — notably Germany — the Gesellschafterliste is filed with the commercial register and is publicly accessible. In others, the share register is private and not disclosed without a court order or the company's consent.
Beneficial owner layer. Following the CJEU judgment in C-37/20, EU member states are no longer required to provide unrestricted public access to UBO registers. Access conditions now vary by member state. Outside the EU, regimes range from fully public registers to no register at all. The report states the access condition for each jurisdiction before work begins.
Enforcement and litigation layer. Court registers and insolvency registers show whether the individual is a party to active proceedings, has been subject to a director disqualification order, or appears in a published insolvency file. Negative results in these registers do not certify absence of proceedings: filing dates and publication lags vary.
The firm covers 35 jurisdictions. For any given individual, the relevant jurisdictions are those where the company is incorporated, where the individual holds directorships, and where assets or enforcement activity may be registered.
A single individual may appear as director in one jurisdiction, as beneficial owner in a second, and as a party to litigation in a third. The report consolidates these layers. It does not stop at the first register that returns a result.
Where a jurisdiction maintains no public register for a given layer, the report states that fact explicitly. The absence of a register entry is recorded as a finding, not as a gap in the work.
Official registers record what has been filed. They do not record what has been concealed.
A nominee director is registered in place of the actual controller. The register shows the nominee. It does not show the instruction agreement behind the appointment. The report can identify patterns consistent with nominee use — such as a director appearing across a large number of unrelated companies — but it cannot confirm the existence of a nominee arrangement from register data alone.
A beneficial owner below the disclosure threshold does not appear in the UBO register. In most jurisdictions the threshold is 25% of shares or voting rights. A person holding 24% is not required to register. The report states the applicable threshold for each jurisdiction and notes whether the declared ownership structure reaches or approaches it.
Structures held through trusts, foundations, or bearer instruments may not be visible in any register. Where the chain of ownership passes through such a structure, the report identifies the point at which the chain becomes opaque and states the reason.
Historical data is limited by what has been archived. Some registers retain historical filings; others overwrite current data. Where historical information is not available from the register, the report does not reconstruct it from secondary sources.
The ceiling of what the sources allow is stated before payment. No engagement proceeds without a scope statement that names the registers to be consulted, the access conditions for each, and the layer at which the chain is expected to stop.
Discrepancies between layers are findings, not errors.
A shareholder list filed with the commercial register may show a different ownership proportion than the UBO register entry. This can result from a filing delay, a transfer that was registered in one system but not yet in the other, or a deliberate inconsistency. The report records both figures, identifies the source and date of each, and notes the gap.
A director who appears as resigned in the company register may still appear as an active signatory in a bank filing or a regulatory submission. The report does not resolve this discrepancy; it records it. Resolution requires legal analysis, which is a separate engagement.
Where the individual's name appears in different transliterations across jurisdictions — a common issue for nationals of CIS countries, the Caucasus, and parts of Asia — the report records each variant and the source in which it appears.
Can the report cover an individual who holds positions in multiple companies across different jurisdictions?
Yes. The subject is the individual, not a single company. The report maps all registered directorships and ownership positions that appear in the registers consulted. The scope is agreed before work begins: the client specifies the jurisdictions to be covered, and the firm confirms which registers are accessible in each.
What if the individual does not appear in any register?
Absence from a register is a finding. The report records which registers were consulted, on what date, and what each returned. If an individual expected to appear in a register does not, that discrepancy is noted. The report does not speculate about the reason.
Is the report suitable for use in legal proceedings?
The report is a factual compilation from official sources. It does not constitute legal advice and does not contain legal qualification of the facts established. Whether the material is suitable for a specific proceeding is a question for the legal counsel handling that matter.
How long does the work take?
Turnaround depends on the number of jurisdictions, the accessibility of the relevant registers, and whether any register requires a formal request with a declared legitimate interest. Estimated timelines are provided in the scope statement before engagement begins.
What is the price?
Price depends on the number of jurisdictions and the depth of coverage required. The scope statement provided before engagement includes the fixed price for the agreed scope.
The following register categories are consulted depending on jurisdiction and subject:
Specific register names, URLs, and extraction dates are included in each delivered report. No register is cited in the report without a recorded extraction date on or before the date of delivery.
Source: jurisdiction-specific official registers · verified 2026-10-13
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: Katharina Berg — Partner, Central Europe, VLO Law Firm