Related party transactions concentrate control risk in a single point: the person who approves the transaction and the person who benefits from it may be the same individual, operating through different legal names or nominee layers. Establishing who actually controls the company — and who holds the economic interest — is the first analytical step before any other assessment can proceed.
This report maps the control layer: registered directors, declared beneficial owners, and the gap between what the sources show and what they cannot reach.
What the report establishesRegistered directors and officers by name and appointment date; declared beneficial owners where the register carries that layer; cross-register discrepancies between the two. Sources: national company registers and, where accessible, beneficial ownership registers — verified September 2026. Condition of accessAccess conditions vary by jurisdiction: some registers are open without registration; others require a declared legitimate interest or a national identifier. No single access path covers all 35 jurisdictions in scope. What the sources do not showNominee arrangements, undisclosed economic interests, and informal control exercised outside the registered structure are not visible in any official register. Price tiersSignal €1,350 · Standard €2,850 · Extended €6,300. Fixed price; scope defined before payment.Source: national company registers and beneficial ownership registers across 35 jurisdictions · verified September 2026
The registered director is the person authorised to bind the company. The beneficial owner is the person who ultimately holds or controls the economic interest. In a related party transaction, these two roles may converge in one individual — or they may be deliberately separated to obscure the connection.
Official registers record the director layer with reasonable consistency across jurisdictions. Appointment date, removal date, and the scope of signing authority are typically on file. Where a company has multiple directors, the register shows whether any single director holds sole signing authority — a structural indicator relevant to transaction approval.
The beneficial ownership layer is less uniform. Several jurisdictions maintain a dedicated UBO register. Others embed ownership data in the company register itself, through shareholder lists or capital tables. A third group records nothing beyond the registered shareholder, which may be a holding company in another jurisdiction.
Cross-register comparison — director register against ownership register against filed financial statements — is the baseline method for identifying discrepancies. A director who does not appear as a shareholder but whose connected entity appears as a counterparty in filed accounts is a pattern the sources can surface. Whether that pattern constitutes a related party transaction in the legal sense is a question of qualification, not of registry analysis.
Source: national company registers (director and shareholder layers) · verified September 2026
Control in a corporate structure is rarely held at a single point. The report traces four layers in sequence.
Layer 1 — Registered directors. Names, appointment dates, and any recorded removal. Where the register carries it: nationality, residential country, and date of birth for identity disambiguation.
Layer 2 — Registered shareholders. Names and ownership percentages as filed. Where the shareholder is a legal entity, the chain is followed one level up in the same jurisdiction. Cross-border chains are traced to the point where the next register is accessible.
Layer 3 — Declared beneficial owners. Where a UBO register exists and is accessible to the requesting party, declared beneficial owners are extracted and compared against the shareholder layer. Discrepancies between the two layers are recorded as findings, not as conclusions.
Layer 4 — Filed financial statements. Where annual accounts are on public file, related party disclosures and connected-entity transactions are extracted. This layer frequently surfaces relationships that the ownership register does not show.
The report does not extend to informal arrangements, undisclosed agreements, or economic interests held through instruments that are not registered anywhere.
Source: company registers, UBO registers (where accessible), filed financial statements · verified October 2026
A related party transaction leaves traces in official sources when it is large enough to require disclosure or when it involves a registered entity. The report extracts the following indicators from available sources.
Director–counterparty overlap. If the counterparty to a transaction is a company in which the approving director holds a registered interest, that overlap is visible through cross-register comparison. The register shows the structural fact; it does not characterise the transaction.
Shareholder–counterparty overlap. A shareholder who is also a counterparty — or whose connected entity is a counterparty — appears in filed accounts where related party disclosure is mandatory. The quality of that disclosure varies by jurisdiction and by the size threshold that triggers the requirement.
Nominee indicators. A director appointed on the same date as multiple other companies, with a residential address shared by dozens of other directorships, is a pattern consistent with nominee use. The register records the fact; the report records the pattern.
Ownership chain interruptions. A shareholder that is a shelf company in a jurisdiction with no public ownership data represents a point where the chain cannot be continued from official sources. The report names the interruption point and the reason.
None of these indicators constitutes a finding of wrongdoing. Each is a structural observation from official sources, recorded for the instructing party to assess in context.
Source: company registers, filed financial statements, beneficial ownership registers (where accessible) · verified October 2026
The report covers 35 jurisdictions. Access conditions, data depth, and update frequency differ materially across them.
| Jurisdiction group | Director layer | Ownership layer | UBO layer | Filed accounts |
|---|---|---|---|---|
| Western Europe (EU/EEA) | Typically public | Typically public | Accessible subject to post-CJEU C-37/20 restrictions | Typically public above threshold |
| UK and Ireland | Public, OGL licence | Public (PSC register, UK) | PSC register (UK); CRO (Ireland) | Public above threshold |
| Central and Eastern Europe | Public | Public or partial | Varies by jurisdiction | Varies |
| CIS and Caucasus | Partial | Partial | Not available in most | Limited |
| Offshore and holding jurisdictions | Registered agent only | Not public | Not available | Not required |
The table reflects general access conditions as of the verification date. Specific access conditions for each jurisdiction are stated in the report before delivery.
For jurisdictions in the offshore and holding group, the report records what is available — registered agent name, incorporation date, registered address — and states explicitly what is not accessible and why. A report that names the limit of the sources is more useful than one that omits the question.
Source: national company registers across 35 jurisdictions · verified October 2026
Official registers record what was declared to them. They do not record what was not declared.
Nominee directors. A nominee director is registered as the director of record. The register shows the name. It does not show the existence of a nominee agreement or the identity of the instructing principal. Where nominee patterns are visible from structural indicators — shared addresses, simultaneous appointments across many companies — the report records those indicators. The underlying agreement is not in any public source.
Undisclosed beneficial owners. Where a UBO register exists, it records what was declared. Declarations are made by the company itself. An incorrect or incomplete declaration is not detectable from the register alone; it requires cross-reference with other sources and, in some cases, produces an irresolvable discrepancy.
Post-CJEU C-37/20 access restrictions. Following the Court of Justice ruling in November 2022, EU member states are not required to provide public access to UBO registers. Access conditions vary by member state. In several jurisdictions, access requires a demonstrated legitimate interest. The report states the access condition for each jurisdiction before delivery.
Offshore chains. Where the ownership chain passes through a jurisdiction that does not maintain a public register of beneficial owners — or where the register is not accessible to foreign requesters — the chain cannot be continued from official sources. The report names the last accessible link and the jurisdiction where the chain terminates.
Filed accounts as a proxy. Where direct ownership data is unavailable, filed financial statements sometimes carry related party disclosures that identify connected entities. This is a secondary source, not a substitute for the ownership register. Its reliability depends on the quality of the audit and the disclosure threshold in the relevant jurisdiction.
The ceiling of what the sources allow is stated before payment. No report is delivered without a prior statement of what it can and cannot establish.
Discrepancies between sources are findings in their own right.
A director who appears in the company register but not in the UBO register — where the UBO register exists and is current — is a discrepancy. It may reflect a filing lag, an error, or a deliberate omission. The report records the discrepancy and the date of each source extraction.
A shareholder recorded in the company register whose ownership percentage differs from the percentage disclosed in filed financial statements is a discrepancy. It may reflect a capital change between filing dates or an error in one of the sources. The report records both figures and both source dates.
A counterparty named in filed accounts whose registered details do not match any entity in the jurisdictions covered is a discrepancy. It may reflect a transcription error, a dissolved entity, or a name that does not correspond to any registered company. The report records the name as filed and the result of the register search.
Discrepancies are not conclusions. They are the points at which the sources stop agreeing and the instructing party must decide what further steps, if any, are warranted.
Source: cross-register comparison across company registers, UBO registers and filed financial statements · verified October 2026
| Tier | Price | What is included | Not included |
|---|---|---|---|
| Signal | €1,350 | Registered directors and shareholders in the primary jurisdiction; UBO register extract where accessible; summary of discrepancies between director and ownership layers; statement of source limits | Multi-jurisdiction chain tracing; filed financial statement analysis; related party disclosure extraction; nominee pattern analysis |
| Standard | €2,850 | All Signal content; ownership chain traced across up to 10 jurisdictions; filed financial statements extracted and related party disclosures identified; nominee pattern indicators recorded; discrepancy report across all sources | Jurisdictions beyond 10; legal qualification of findings; enforcement or litigation support |
| Extended | €6,300 | All Standard content; full 35-jurisdiction coverage; cross-register discrepancy analysis across all layers; offshore chain termination points identified and documented; structured findings report with source citations and extraction dates | Legal qualification of findings; enforcement or litigation support; any source that is not an official register or public filing |
This report is a factual compilation from official registers and public sources. It does not constitute legal advice and contains no legal qualification of the facts established.
What triggers the need for this report? A related party transaction becomes a concern when the person approving it and the person benefiting from it may be connected. The report establishes whether that connection is visible in official sources. It does not determine whether the transaction was proper or improper — that is a legal question outside the scope of registry analysis.
What if the company is registered in a jurisdiction with no public ownership data? The report records what is available in that jurisdiction — typically the registered agent name, incorporation date, and registered address — and states explicitly what is not accessible and why. The ownership chain is traced to the last accessible link. The termination point is documented.
How long does the report take? Delivery time depends on the number of jurisdictions in scope and the access conditions of each register. Signal tier reports covering a single primary jurisdiction are typically delivered within five to seven business days. Extended tier reports covering all 35 jurisdictions require a longer timeline, stated at the time of the request.
Can the report be used in legal proceedings? The report is a factual compilation with source citations and extraction dates. Whether it is admissible or useful in a specific proceeding depends on the rules of that proceeding and the jurisdiction in which it takes place. That assessment is outside the scope of this report.
What happens if a discrepancy is found? Discrepancies are recorded as findings with the source, the date of extraction, and the nature of the discrepancy. The report does not resolve discrepancies or characterise their significance. The instructing party decides what further steps are warranted.
Is the price fixed before the report starts? Yes. The price is fixed by tier. The scope of each tier is defined before the report begins. The ceiling of what the sources allow is stated before payment.
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