A beneficial owner is an individual who, directly or indirectly:
Exercises Substantial Control: This means having the authority to make significant decisions for the reporting company, regardless of actual ownership. Some examples include senior officers such as CEOs and COOs, those with the power to appoint board members, or individuals who direct, or enter into important contracts.
Owns or Controls at least 25% Ownership Interests: Any individual holding 25% or more ownership interests, be it in the form of shares, membership in an LLC, or convertible notes, is considered a beneficial owner. This calculation is per individual, including indirect ownership through entities like LLCs.