Don’t Forget to Update Information on UBOs in Ukraine

We would like to inform you that new form of the ownership structure of legal entities has already been adopted and published by the Ukrainian government. The relevant regulation comes into force on 11 July 2021.

Now, according to the requirement of the new Law on Anti-Money Laundering ("Law"), all legal entities are obliged to:

• disclose their ultimate beneficial owners ("UBOs") or confirm information regarding their UBOs before 11 October 2021, and
• perform an annual confirmation of their UBOs and to notify the government regarding changes in the UBOs’ structure in a timely manner.

Information on the UBOs must be disclosed/confirmed in accordance with the approved form of the ownership structure. The ownership structure should be presented in the form of a schematic image indicating all persons/entities who own a legal entity or exercise control. The Cabinet of Ministers of Ukraine has also defined the scope of the information on such persons/entities that needs to be presented in the schematic image.

Please be also informed that introducing any changes about the legal entities in the Companies Register will be impossible without the prior proper submission of information on UBOs.

Failure to comply with the above requirements will lead to the imposition of a penalty for the director of the legal entity in an amount up to UAH 51,000.

Should you have any questions or require our assistance with the above, please do not hesitate to contact us.