Following the Court of Justice of the European Union's judgment in joined cases C-37/20 and C-601/20, public access to UBO registers across the Union has been restructured. Cyprus has aligned its register, providing access to competent authorities, obliged entities for AML purposes, and persons demonstrating a legitimate interest.
For groups, the underlying obligations have not changed:
— Identify and document the beneficial owner(s) by reference to ownership and control.
— File and maintain UBO information with the Registrar of Companies within prescribed deadlines.
— Reflect the same analysis at the level of express trusts and similar arrangements through the dedicated trust register.
Non-compliance attracts administrative fines on a per-day basis and is a frequent finding in supervisory inspections of obliged entities. Following the AML Package, the AMLA will further harmonise expectations across the Union.
Corpora maintains UBO records for hundreds of corporate and trust structures and supports clients with periodic re-verification exercises.
