In Norway the official UBO register is not yet fully populated. So the best public source of information the public shareholder register (Aksjonærregisteret) which is updated once every year, usually in May, based on the shareholdings by 31st of December the previous year. Based on that information, Strise does the following calculations to find the Ultimate Beneficial Owner (UBO) of a legal entity (the target entity). For companies certain legal forms that typically don’t have shareholders, role data is used to determine beneficial owners.

More than 25% direct ownership

A physical person directly owning more than 25% of the target entity is classified as a UBO

More than 25% ownership through a trail of legal entities

A physical person that owns more than 25% of a legal entity that in its turn owns more than 25% of the target entity is classified as a UBO. The trail of legal entities can be up to X legal entities for Strise to classify a physical person as a UBO.

More than 0,5 voting power

It is possible to build an ownership structures a physical person may have way more control than the ownership percentage indicates. Two examples are:

Circular ownerships:

• John Doe owns 10% of Company A
• The other 90% of Company A is owned by Company B
• Company A owns 100% of Company B

Then John Doe is the ultimate beneficiary of both Company A and Company B, even if the ownership percentage is at only 10%.

Tie breaker votes:

• John Doe owns 4% of Company A
• 48% of Company A is owned by HoldingCompany 1
• 48% of Company A is owned by HoldingCompany 2
• HoldingCompany 1 is owned by John Doe (2% ownership), Owner B (49% ownership) and Owner C (49% ownership)
• HoldingCompany 2 is owned by John Doe (2% ownership), Owner D (49% ownership) and Owner E (49% ownership)

John Doe owns less than 6% of Company A, but he needs support from just one of the other owners to control the company. The four other owners needs support from John Doe, or from all the other owners to control the company.

Voting power: