In my view, we should follow current procedure to identify UBO that is individual person holding share equivalent to 25 % of our merchant per current threshold set in UBO policy. Sanctions Screening Standard is set at 50% but country procedure set at 25% to aligned with UBO policy. Hence in case that cannot drill down to individual with 25% share this could be deviate at country level.
I need to seek opine on this from Regional due to UBO may not required to fully apply for merchant in the same way as it is required for customer due diligence