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Ukraine updates requirements for information disclosure on UBOs and ownership structure

Ukraine
02/07/2021
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On 11 June 2021, Ukraine's Ministry of Finance issued Order No 163 “On Approval of the Regulations on the Form and Content of the Ownership Structure”, establishes the form of the ownership structure (i.e. corporate organisational chart) of a company to be submitted to a state registrar (the Ownership Structure).

The Ownership Structure should:

  • illustrate – in the form of a schematic - connections between individual persons and legal entities, trusts, and similar establishments within the companies’ group (including the names of all entities in the company’s ownership chain) and enable the identification of each ultimate beneficial owner (UBO); or
  • confirm that there is no UBO of the company (e.g. because the ultimate parent company is a publicly traded company). The nature of influence of each UBO on the company’s activities should also be described in the form published by the Ministry on its website.

The Order enters into force on 11 July 2021. By 11 October 2021, legal entities incorporated and existing under Ukrainian law will be required to either disclose the above information and provide the necessary confirmatory documents, or confirm the absence of UBOs to the state registar (the Disclosure). Failure to do so or a late Disclosure may result in a fine of up to UAH 51,000 (EUR 1,570).

Certain types of legal entities are exempt from the Disclosure requirement. These include attorneys’ associations, non-governmental public formations (e.g. non-governmental organisations, trade unions and other non-profit organisations), state bodies, and state and municipally owned enterprises.

Previous CMS updates on the UBO disclosure requirements can be found here.

For more information on compliance requirements for disclosure of information on UBOs in Ukraine, contact your CMS client partner or local CMS expert.

Legislation: Order of the Ministry of Finance No 163 dated 19 March 2021 “On Approval of the Regulations on the Form and Content of the Ownership Structure” (in Ukrainian).

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