One of the most significant changes in 6AMLD: The 6th Anti-Money Laundering Directive is the restriction of Public Register access for Ultimate Beneficial Owner (UBO). While the EU is working on a centralized access system (Beneficial Ownership Secure Search System (BORIS)), uncertainty remains regarding who will be granted access, under what conditions, and how this will affect Know Your Customer (KYC) workflows for Danish companies.

Public Register Access: What’s Changing?

• UBO access restrictions: It’s unclear whether third-party providers (e.g., financial crime software platforms) will have direct access.
• Country-specific access controls: Companies may need to apply separately in each EU member state to access data.
• 28-day rule: Changes in UBO structures must be registered within 28 days, adding pressure to maintain up-to-date records.

Additionally, businesses will be required to register more details about UBOs, including:

• Place of birth
• Nationality/citizenship
• Residential address
• Detailed ownership/control structures
• The individual responsible for storing UBO data

These updates will increase the compliance burden for businesses, making self-declaration and Verification more complex.

The Impact on KYC and Financial Crime Compliance

With more limited access to public UBO data, businesses may need to:

• Rely more on self-reported information from counterparties.
• Develop stronger internal KYC frameworks for verification.
• Implement structured audit trails to meet new compliance testing requirements.

Regulated companies will also face mandatory external AML audits - another key AMLD6 requirement - to ensure policy compliance and data integrity.

How to Stay Ahead

The restricted availability of public UBO data creates challenges but also reinforces the importance of secure, structured KYC collection. Businesses must ensure they:

• Use a centralized KYC platform to store and update UBO information.
• Implement internal compliance audits to track data collection accuracy.
• Adapt to stricter Due Diligence (DD) timelines with automated workflows.

While AMLD6 introduces tighter controls, proactive businesses can streamline compliance efforts with the right technology, processes and advisory support.

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