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Ukrainian legal entities must disclose their UBOs - The form of ownership structure has been adopted

9 July 2021 – On 11 July 2021, an Order of the Ministry of Finance of Ukraine dated 19 March 2021 “On approval of the Regulation on the form and content of an ownership structure” enters into force. The Order sets out the required details concerning ownership structure that must be submitted by legal entities to the state registrar in order to disclose their ultimate beneficial owners.

Within three months from the date that the Order takes effect, legal entities must submit to the state registrar the information on their ultimate beneficial owners to the extent specified by Ukrainian legislation.

Legal entities must also submit their ownership structure to the state registrar:

  • for the state registration of a legal entity;
  • in the event of any changes to the information about the legal entity recorded in the Unified State Register;
  • within 30 working days from the date of changes in the ownership structure of the legal entity and/or the composition of its ultimate beneficial owners;
  • annually within 14 calendar days from the date of state registration of a legal entity.

New requirements for the disclosure of information on ultimate beneficial owners to the state registrar were established by the Law of Ukraine “On Prevention and Counteraction to Legalisation (Laundering) of the Proceeds of Crime, Financing of Terrorism and Proliferation of Weapons of Mass Destruction” dated 6 December 2019. However, the implementation of the legislative requirements was deferred until the development and adoption of the form and content of ownership structure.

For more information please contact Illya Muchnyk, Counsel,

e-mail

, and Oleksandra Poliakova, Senior Associate, .