As we have already informed, on 25 May 2015 the deadline for Ukrainian legal entities to submit information on their ultimate beneficial owners was expected to expire. However, due to the fact that a large number of companies failed to submit such information in time, the draft Law of Ukraine “On Introduction of Amendments to Certain Laws of Ukraine in Respect of Information on the Ultimate Beneficial Owner (Controller) of a Legal Entity” (the “Law”) was urgently prepared. The Law was adopted by the Verkhovna Rada of Ukraine on 21 May 2015 and took effect as from 26 May 2015.   

The Law provides for an extension of the deadline for legal entities to submit information on their ultimate beneficial owners to the State Registrar from 25 May 2015 to 25 September 2015. The Law also releases, in particular, religious organizations and legal entities the participants of which are individuals only, if such individuals are ultimate beneficial owners of such legal entities, from the obligation to submit information on their ultimate beneficial owners.

In addition, the Law has settled the matter related to the absence of the ultimate beneficial owner (controller) of a legal entity. Now in such cases the information about the absence of the ultimate beneficial owner (controller) shall be submitted to the State Registrar.

In case a legal entity (except for legal entities released from this obligation) fails to submit the information on the ultimate beneficial owner or on the absence of the ultimate beneficial owner by 25 May 2015, such failure entails the imposition of a fine in the amount of 300–500 untaxable minimum incomes of citizens (from UAH 5100 to UAH 8500) on the director of such legal entity.