Hans Urlus, Maquina Lamé and Rabia Simsek authored this Practice Note that explains the requirements for Dutch entities and trusts to register and maintain information on their Ultimate Beneficial Owners (UBOs) in the Dutch UBO and Trust Registers. This Practice Note provides guidance on which entities must register, the criteria for identifying an UBO, and the registration process. It explores the ongoing obligations for entities, the process for shielding UBO data for protected persons, and the reporting duties for institutions subject to anti-money laundering (AML) laws when discrepancies are found. A key focus is the impact of the November 2022 European Court of Justice (ECJ) judgment that suspended public access to the UBO Register and the subsequent legislative changes limiting access to parties with a legitimate interest. The Practice Note also outlines the sanctions for non-compliance.

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