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New disclosure rules for end beneficiaries of companies in Ukraine

On April 28, 2020, a new Law No. 361-IX of December 6, 2019, which provides for new rules for disclosure of final beneficiaries of legal entities, will enter into force.


In case of registration of a legal entity or modification of the information already contained in the CDU, it will be necessary to submit documents that will sufficiently disclose the ownership structure of the company. At the same time, this applies also to those legal entities that were created before the new law came into force.


What to tell the registrar?


To disclose the ownership structure, you will need to submit 1) your own ownership structure, 2) an extract confirming your registration in the country of residence (for legal entities) or a notarized copy of your passport (for individuals).


However, what the "ownership structure" will look like is currently unknown, as its form and content must be approved by the State Financial Monitoring Service of Ukraine in agreement with the Ministry of Justice of Ukraine.


Beneficiary information will need to be provided even when all the founders are individuals.


When to submit information?


Legal entities registered before April 28, 2020, submit to the State Registrar information about the final beneficial owner under the new rules within three months after the enactment of the act approving the form and content of the ownership structure.


In addition, the information on the final beneficiary will need to be constantly updated. Each year, within 14 calendar days of the date of registration, you will need to submit not only the application for confirmation of information about the beneficiary, but also the complete package of documents, provided in case of initial registration or introduction of changes, - ownership structure, statement for beneficiaries-legal entities or notarized a copy of the passport for beneficiaries-individuals.


If the information about the beneficiary changes, you must notify the state registrar of such changes within 30 working days of their occurrence, as well as submit documents confirming such changes.


What is the sanction for the violation?


From April 28, 2020 violators will be fined from UAH 17,000 to UAH 51,000 for the head of the legal entity. They will be punished for failure to submit or late submission to the State Registrar of information about the beneficiary or lack thereof, as well as for failure to submit documents to confirm such information.


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