Ultimate Beneficial Owner Register – Penalties During the Interim Solution Period

Further to our previous newsfeeds on this matter, on 25 May 2021 the Registrar of Companies announced that no penalties will be imposed during the interim solution period, including in the following cases:

-       companies established before 12 March 2021, for which Ultimate Beneficial Owner (UBO) data must be submitted by 12 March 2022;

-       companies established after 12 March 2021, for which UBO data must be submitted within 30 days from the date of their registration;

-       changes in reportable information for which data must be submitted within 14 days.

It is reminded that the interim solution refers to the period during which access to the UBO Register is only available to the Competent Supervisory Authorities, the Financial Intelligence Unit, the Customs Department, the Police and the Tax Department, upon request to the Registrar of Companies. Therefore, information in the Register is not publicly available during this period. At the final stage the information collected will be transferred to a platform through which it will be accessible to any person or organisation that can demonstrate a legitimate interest, based on the provisions of the 5th EU AML Directive (EU 2018/843).

It is also reminded that the penalty for non-compliance is €200 for the entity and each of its officers plus €100 for every day thereafter for which the default continues, with a maximum of €20.000 for each default.

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