As a result of the amendment, legal entities and entities without legal personality will be obliged to report beneficial owner(s) to the central register. Within 5 days after the commencement of their activities or the change, the beneficial owner(s) must be reported to a central register established for the purpose of storing the information.

Service providers, such as accountancy, audit, tax advisory firms and supervisory bodies, such as registry court, are required to file a report if they observe discrepancies between the beneficial ownership information that are contained in the register and the actual information available to them.

Supervisory bodies have unrestricted access to the register.  Service providers are entitled to request data from the register with direct access to perform customer due diligence.

The creation of a central register was first included in the 2017 amendment to the Anti-Money Laundering Act, but the practical application of the amendments could not take place in the absence of a central register.

Under the current regulations, service providers subject to the Anti-Money Laundering Act are obliged to report the beneficial owners of their customers until 1 March 2021 at the latest.

At the time of publication of this article, there is no such a central register yet where service providers can fulfill this obligation.

This article will continuously be updated.