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Changes in Central Register of Beneficial Owners

On December 31st, 2021, changes to the Act on Combating Money Laundering and the Financing of the Terrorism in the scope of Central Register of Beneficial Owners (“Register”), came into force. As usually in such situations, obligations were extended.

Entities to be entered to the Register

The most important change is extension of the list of entities which have to be entered into the Register, after which that list looks as follows:

  • general partnerships,
  • limited partnerships,
  • joint-stock partnerships,
  • limited liability companies,
  • simple joint stock companies,
  • joint stock companies (excluding public joint stock companies),
  • professional partnerships,
  • European economic interest groupings,
  • Societas Europeas,
  • co-operatives,
  • Societas Cooperativas Europeas,
  • associations entered into National Court Register,
  • foundations,
  • trusts whose trustees or persons on equal positions, are domiciled or seated in Poland or enter into business relations or acquire real estate in Poland, on behalf or for the trust.

Scope of information to be reported to the Register

Scope of information which shall be reported by the obliged entities, slightly changed. Under new regulations, the following shall be reported:

  • data identifying entity,
  • information on all beneficial owners of the entity determined according to the law in force,
  • information on person or persons submitting application (usually persons entitled to represent the entity).

Information on all citizenships

Before the changes, a citizenship of beneficial owner had to be submitted to the Register. Now it is extended onto all citizenships of the beneficial owner.

Deadline for submitting new informations

Professional partnerships, European economic interest groupings, Societas Europeas, co-operatives, Societas Cooperativas Europeas associations entered into National Court Register and foundations, entered into the National Court Register and trusts existing before October 31st, 2021, are obliged to report beneficial owners to the Register until January 31st, 2022. Above entities entered into the National Court Register or created (in case of trusts) after October 30th, 2021, are obliged to report beneficial owners to the Register at latest within 7 days after entering to the National Court Register.

Tomasz Korolko
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