KYB for non-US entities operating within the US: How are you handling the UBO/compliance curveball?

Been wrangling with a particular issue recently, hoping to get some practical insights from others navigating this space. We're a fintech operating in the US, providing services to a growing number of non-US entities. The core challenge isn't just the initial KYB – we've got our processes fairly buttoned down for standard documentation. It's the ongoing UBO verification, especially when dealing with complex foreign ownership structures, trusts, or shell companies in jurisdictions with less transparent registries.

The beneficial ownership information (BOI) rule under the CTA has obviously ramped up requirements for US entities, but the nuance for non-US entities operating within the US market, particularly around identifying and verifying ultimate beneficial owners (UBOs) for AML purposes, feels like a constant tightrope walk. Are you finding your existing third-party data providers are keeping up with the jurisdictional complexities? Are you seeing more reliance on manual outreach and attestations, and if so, how are you mitigating the associated risk? The cost-benefit of deep-diving into every layer for smaller entities can quickly become prohibitive, but the regulatory risk of not doing so is even higher. Interested to hear what others are doing to manage this effectively without drowning in red tape or missing critical red flags. Is anyone seeing specific tech solutions or best practices emerge for this specific challenge?