Following Ukraine’s 2020 implementation of anti-money laundering legislation requiring companies to disclose ultimate beneficial owners, the country’s Ministry of Finance announced new guidelines on reporting ownership structures and outlined the details required to do so.
Ukrainian legislation defines an ultimate beneficial owner as an individual exerting decisive influence or control over a company’s activities and/or an individual on whose behalf financial transactions are being conducted. The individual must have ownership of at least 25% of the entity’s capital or voting rights.
The new guidelines – Regulation on the Form and Content of an Ownership Structure (in Ukrainian) – came into effect on July 11, 2021, and requires that legal entities registered in Ukraine must:
- Provide an illustration of the ownership structure showing connections between individuals and legal entities, trusts, and similar establishments within the companies’ group. The document must include the names of all entities in the company’s ownership chain and enable the easy identification of each UBO.
- In the absence of UBOs meeting the criteria set forth (e.g. the parent company is a publicly traded entity), companies must provide confirmation to the local registrar.
- Additionally, the nature of the influence of each UBO on the company’s activities should be described in the documentation provided to the registrar.
Existing Ukrainian companies must submit their UBO information with all required documentation to the local companies register by October 10th, 2021. New entities must provide this information upon registration. Failing to comply with this requirement or submitting a late disclosure may result in fines.
Moving forward, UBO information in Ukraine must be updated annually, within 14 days after the close of each year. Changes to ownership structure or owner details must be reported within 30 days of the change taking place.
For more information on complying with Ukraine’s beneficial ownership requirements and ensuring the compliance of your international entities, contact a CT representative at (844) 322-6993 (toll-free U.S.).
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