To secure the transparency required to fight money laundering and terrorism financing pursuant to the EU Anti-Money Laundering (AML) Directives, the Netherlands will now implement a public register of Ultimate Beneficial Owners (UBOs). On June 23, 2020, the Dutch Senate adopted the implementation act needed to create this UBO register.

The Act may go into effect presumably not later than by September 2020, at which time all newly established entities must submit for public registration in the trade register (maintained by the Dutch Chamber of Commerce) information to identify their UBOs. Existing entities are afforded some leeway and must register their UBOs within 18 months from the effective date of the new legislation. The registration obligation has no retroactive effect. Accordingly, entities already in existence when the act takes effect do not need to register individuals who qualified as UBOs between the implementation of the UBO register and the first registration, but who are no longer a UBO at the date of registration.

Read the full GT Alert, “Dutch Ultimate Beneficial Owner (UBO) Register Implementation.”