Practical due diligence cases for domiciliation centers: 5 concrete scenarios

In brief

Due diligence at a Belgian domiciliation center is not just about ticking a checklist. Five concrete situations illustrate the gray zones: a recently incorporated company with a non-resident UBO, abnormal director rotation, uncollected official mail, a reactivated shell company, and a UBO/register mismatch. For each case, the AMLCO must cross-check BCE data, the Belgian UBO register and professional judgement, then document the decision in writing.

Why practical cases

AML theory is well documented. The daily difficulty for a Belgian domiciliation center lies in the judgement on ambiguous situations where the checklist does not decide and the AMLCO must. This article offers 5 anonymized practical cases, representative of 2025-2026 situations, with for each:

• The factual context

• Detected red flags

• The analysis steps

• The decision taken and its written justification

• Lessons to draw

For the general framework, see the new 2024 domiciliation obligations.

Case 1 — Recent company with non-resident UBO

Context

A domiciliation request for an SRL incorporated 3 months ago, with:

• Corporate purpose: "international trade of various products"

• Desired office: your center in Brussels

• Capital: €100 (legal minimum)

• Director: Belgian resident natural person

• UBO 100 %: Moldovan national, resident in Dubai

Detected red flags

• Recently incorporated company (< 12 months) with non-resident UBO

• Too generic corporate purpose

• Minimal capital

• Parties' residence jurisdictions: combination Moldova + UAE (two countries on enhanced vigilance lists)

• Local director potentially nominee

Analysis steps

BCE pre-fill: verify official elements

UBO cascade: verify in the Belgian UBO register

Sanctions/PEP screening: the Moldovan UBO must be cross-checked with EU/UN/OFAC lists

Additional request: precise business model (target clients, suppliers, geographies)

Source-of-funds evidence: €100 capital but significant volumes expected later

Local director verification: their CV, effective role, other mandates

Decision

Refusal or acceptance under enhanced conditions, depending on elements:

• If business model coherent (e.g. import of products whose sources the UBO masters), clean screening and source documented → acceptance with enhanced measures: quarterly monitoring, transaction cap, mail mandatorily collected within 15 days

• If vague elements, justified refusal

Documentation

AMLCO note dated and signed justifying the high risk assessment, enhanced monitoring plan, domiciliation contract with specific clauses (quarterly audit, immediate termination right).

Lesson

A recent company + non-resident UBO from a sensitive jurisdiction is not an automatic refusal, but imposes a different monitoring framework from the standard.

Case 2 — Repeated director changes

Context

A client domiciliated for 2 years has changed director 4 times in 18 months. The company is active (accounts filed on time), no apparent incidents. But the pace of changes is striking.

Detected red flags

• Abnormal management rotation

• No apparent logic (no growth, no announced restructuring)

• Possible fronting: successive directors as screens for a UBO not wanting to appear

Analysis steps

BCE cross-check: retrieve director history

Profile of each director: were they already directors of other companies? Links between them?

UBO register comparison: has the UBO cascade been updated?

Interview current director: real knowledge of activity, decision autonomy

Enhanced monitoring of operations over 12 months

Decision

• Written explanation request to the client (without revealing the specific suspicion)

• If explanation coherent (e.g. temporary directors during legal transition) → log in file

• If explanation confused or contradictory → consider CTIF report and termination

Lesson

The rate of change is a weak but cumulative indicator. Always cross-check with other signals before concluding.

Case 3 — Uncollected official mail

Context

A company domiciliated at your center receives a registered letter from the tax authority. You notify the client by email and SMS. After 30 days, the mail has not been collected.

Detected red flags

• Client absence / disinterest in official communications

• Possible sign of non-operational shell company

• Risk of complicity by non-transmission

Analysis steps

BCE verification: is the company still active?

Contact attempts: multiplied (phone, registered)

Activity verification: recent accounts filings, VAT returns

Examine domiciliation contract: what does it provide for this case?

Decision

Per standard SPF Economie contracts post-RD 22/04/2024:

• Written notice to the client (registered)

• If no response within 15 days: termination of contract

• BCE notification of imminent address change

• If shell-company suspicion: CTIF report

Lesson

Uncollected mail is a systematic control point since the 2024 RD. No compliant center can let it pass.

Case 4 — Request for a re-activated company

Context

A requester wants to domiciliate a company still listed as active in BCE, but whose corporate purpose was recently modified from "textile trade" to "multi-sector import-export", and whose capital was increased from €100 to €100,000 via cash contribution.

Detected red flags

• Reuse of a shell company (old company, little activity, suddenly reactivated)

• €100,000 cash contribution without source justification

• Corporate purpose emptied then re-broadened

• Possible cover structure for undeclared activity

Analysis steps

BCE history: follow 5-year evolution (names, directors, purpose)

Annual accounts: filed? Real activity visible?

Source of funds: justification of contributed capital (UBO contribution, loan, other)

UBO profile: new or historical?

Full UBO cascade including intermediary holdings

Decision

If source of funds not clearly justified → motivated refusal.

If everything coherent (e.g. former shareholder reactivating company for new activity, with documented contribution) → acceptance with enhanced measures and quarterly monitoring.

Lesson

A reactivated shell company is a classic cover attempt signal. Always document source of funds before onboarding.

Case 5 — UBO mismatch BCE / Register

Context

At an annual KYC renewal, you compare the automatically retrieved UBO cascade with the Belgian UBO register. Observation: the register indicates Mrs. Martin (60 %) + Mr. Dupont (40 %), but the client just provided an org chart indicating Mrs. Martin now holds 100 %.

Detected red flags

• Divergence between client declaration and official register

• Possible forgotten UBO update by the client (frequent case)

• Possible concealment of a real UBO (more serious case)

Analysis steps

Written confirmation of current composition

Evidence of share transfer (notarial deed, published statutory modification)

Verification that the modification was registered at the enterprise court

Reminder to the client of their UBO update obligation within the month

Documentation of the divergence in your KYC file

Decision

If divergence explainable (forgotten MyMinFin update):

• Invite client to regularize within the month

• Document the incident

• Monitor effective regularization

If divergence not justifiable or Mr. Dupont not mentioned in received org chart:

• Suspicion of UBO concealment

• Consider CTIF report

• Possible termination

Lesson

The systematic cross-check declared UBO / register UBO is now central in AML. One of the most controlled points in inspection.

How Company Belgium tools these cases

The Company Belgium domiciliation module natively provides analysis elements for each case:

• BCE pre-fill + 5-year history (director changes, name, corporate purpose, capital)

• Automatic UBO cascade with Belgian register comparison → divergences flagged

• Watch: alerts on changes (new director, accounts filing, UBO change)

• Mail monitoring: package logging, 15-day alerts

• Integrated decision log to document each case

• CTIF module: report on suspicion with goAML generation

• Contract templates for domiciliation post-RD 22/04/2024

See also the 2026 checklist, the 2024 domiciliation obligations and the risk assessment methodology.

Bottom line

Due diligence does not boil down to ticking boxes. These 5 practical cases illustrate gray zones where the AMLCO must decide by crossing weak signals, external verifications and professional judgement.

The common thread: document every decision in writing, whether it leads to acceptance, conditional acceptance, refusal or CTIF report. That is what makes the difference between a file that holds up in inspection and one that collapses.