We would like to bring to your attention an important announcement from the Department of Registrar of Companies and Intellectual Property regarding the registration of Ultimate Beneficial Owner (UBO) details in the Registry of Ultimate Beneficial Owners (RUBO).
Implementation of the “Final Solution” Electronic System for UBO
We are pleased to inform you that the implementation of the “final solution” for the electronic UBO system will commence on November 14, 2023. This system will play a crucial role in ensuring transparency and compliance with UBO regulations.
Action Required for All Organizations
All companies established or registered under the Companies Law, Chapter 113, all European Public Limited Liability Companies (SE), and all Cooperatives, or their officials/partners, are mandated to enter the “final solution” system and perform the “Initial Registration” action. This action requires updating or re-entering corporate data, even if such information has previously been submitted through the “intermediate solution” system.
Phase A – No Fines During This Period
Phase A of the implementation will span approximately 1 ½ months, from November 14, 2023, to December 31, 2023. During this phase, no fines will be imposed, offering organizations an opportunity to ensure compliance without financial penalties.
Phase B – Fines for Non-Compliance
However, organizations that fail to enter the “final solution” system during Phase A to perform the “Initial Registration” action will be subject to fines. This fine will be effective from January 1, 2024, and will continue until the date of the “Initial Registration” action when the final solution system will be updated with UBO information.
Phase C – The following actions will be available:
1. Updating the Registry of Ultimate Beneficial Owners
2. Confirmation of Ultimate Beneficial Owners
3. Correspondence
4. Electronic Searches in the Registry of Ultimate Beneficial Owners
5. Requests for exemption from disclosure of information
6. Requests for access to the data of a minor
7. Calculations of financial charges where applicable
We encourage all organizations to familiarize themselves with these actions and ensure that they are in compliance with the regulatory framework.
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