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Corporate program only:This page applies to Corporate Programs.
In the Rain system, an Ultimate Beneficial Owner (UBO) is an individual who holds significant control over a company applying for a corporate card program. This concept is required under compliance rules and is essential to the company application process.

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UBO definition under compliance rules

A UBO is any individual who meets at least one of the following criteria:
  • Owns 25% or more of a company’s shares.
  • Controls 25% or more of a company’s voting rights.
  • Exercises significant influence over the company in another way.
All companies have at least one UBO, but UBOs do not need to be Rain users. Instead, they are listed as part of the corporate application.

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What representatives and UBOs submit

Verifying a business also means verifying the people behind it. A corporate application includes its representatives (authorized signers) and its UBOs, and the two submit different things:
  • Representatives provide the same personal information as a consumer applicant and are screened as soon as they are added.
  • UBOs provide the same personal information and an identity document, but no selfie. Under Standard Compliance, UBO checks are reviewed by Rain’s compliance team rather than requested automatically; under Hybrid Compliance, UBO checks run automatically alongside representatives.
For the consumer field list both roles draw on, see Verification requirements & screening.

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UBOs in the Rain system

Identifying UBOs is a crucial step in the corporate application process, ensuring compliance and verification of company ownership. The following questions cover UBOs and their role in the application process.
Yes. A company application cannot be fully approved until all UBOs have been processed.
No. The individual created in the application step is not necessarily a UBO. UBOs are listed in the application’s own ultimateBeneficialOwners array, separate from its representatives; a person who is both appears in both.
There are two distinct roles in a corporate application:
  • UBOs: individuals who own 25% or more of the company.
  • Representatives: people authorized to act on behalf of the company during the application.
Yes, but Rain does not recommend this. The company will not be fully approved until all required UBOs are added and verified.
There is no fixed limit. Depending on its ownership structure, a company may have one UBO or hundreds.
Yes. UBOs must be processed and approved before the company can start issuing cards.
Each UBO provides personal information and an identity document; a selfie is not required for UBOs. Who runs the check depends on your compliance model, as described in What representatives and UBOs submit. For accepted document types, see KYC/KYB documents.

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What’s next

Verification requirements

The field-by-field tables a corporate application draws on.

KYC/KYB documents

Documents required for people and businesses.

Application states

Track the corporate application’s outcome.