Changes in order of disclosure of information about the ultimate beneficial owners of Ukrainian companies

On 28 April 2020, the Law of Ukraine "On Preventing and Counteracting the Legalization (Laundering) of Proceeds of Crime, Financing Terrorism and Financing the Proliferation of Weapons of Mass Destruction" No. 361-IX dated 6 December 2019 comes into force, which provides for new rules on disclosure of ultimate beneficial owners (UBO) of legal entities.

When registering or modifying information about a company, the applicant will be obliged to provide the state registrar with the ownership structure and documents identifying the UBO of the company (for example, an excerpt or a copy of a passport).

Companies registered before 28 April 2020 will be obliged to provide the state registrar with information about the UBO within three months upon the entry into force of a regulatory act approving the form and content of the ownership structure. It is envisaged that the information on the UBO is to be updated annually. In addition, the company will be obliged notify the state registrar on the change of information about its UBO.

The new law also increases the amount of the fine that can be imposed on a company's executive for failure to provide the state registrar with information about the UBO of the company or to submit documents confirming the information provided. From 28 April 2020, the new fine will be from UAH 17,000 to 51,000 (approx. EUR 640 to 1920).

For further information please contact Asters' Partner Vadym Samoilenko or Associate Viktoriia Hut.