On Amending Some Legislative Acts of Ukraine Related to Identification of Ultimate Beneficiaries of Legal Entities and Public Figures

The deadline for the submission of information on beneficial owners of Ukrainian companies registered before 25 November 2014 expires on 25 May 2015.

As we have already informed, on 14 October 2014 the Verkhovna Rada adopted Law of Ukraine No. 1701-VII “On Amending Some Legislative Acts of Ukraine Related to Identification of Ultimate Beneficiaries of Legal Entities and Public Figures,” which, in particular, introduced the requirement to submit information on beneficiaries of Ukrainian legal entities to the State registrar.

Legal entities registered before the Law of Ukraine No. 1701-VII took effect, i.e. before 25 November 2014, were granted a six-month transitional period during which they had to submit the above information to the State registrar. This means that until 25 May 2015 such Ukrainian companies must submit the following information to the State registrar by means of completing and filing a registration card:

  • On the ultimate beneficial owner (controller) of a legal entity, including the information on the ultimate beneficial owner (controller) of its founder, in case the founder is a legal entity.
  • On the ownership structure of founders - legal entities, that enables to identify individuals holding significant participation interest in such legal entities. 

According to Article 166-11 of the Code of Administrative Offences of Ukraine, a legal entity’s failure to submit information on the beneficial owner of the legal entity as stipulated by the Law of Ukraine “On State Registration of Legalities and Individual Entrepreneurs” to the State registrar 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 the legal entity or the official authorized to act on behalf of the legal entity (the executive body).