Of the European countries which are obliged under the Fourth EU Anti-Money Laundering Directive to set up a so-called UBO-register, only Germany, the United Kingdom and Denmark met the 26 June 2017 deadline. This is one of the results of a large-scale investigation by candidate civil law notary Maarten Buma and professional support lawyer Melanie Al-Zafari into the status and expected implementation of the register containing information about ultimate beneficial owners of companies and enterprises (UBOs). Information for the investigation was obtained from law firms in all member states of the EU, the EEA and in Switzerland.

They expect that the survey report will bring order to the chaos, said Maarten. "The UBO register has already caused quite a stir, for instance because in several countries, including the Netherlands, certain information in the UBO register may become accessible to the public. There is reasonable fear that if ownership information about companies is made public, large shareholders and their families will run an increased risk of kidnapping or blackmail. Despite all the criticism, the directive has been adopted and all member states will be establishing a UBO register within the near future. An ultimate beneficial owner who is subject to registration obligations in multiple countries can easily lose track, as a result of differences in effective dates, transitional rules and definitions. To make life easier, we have sorted out the differences and presented them in a single document. By way of example: our report gives a person who is the UBO of a Dutch B.V., a German GmbH, a Belgian N.V. and an Austrian Offene Gesellschaft, a general outline of the registration obligations and deadlines in the aforementioned countries. The report can be considered as a sort of railway timetable."