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New requirements for UBO and ownership structure disclosure in Ukraine

On 11 July 2021, the Decree of the Ministry of Finance of Ukraine “On Approval of Regulations on Form and Content of Ownership Structure” came into force, which has introduced the following novelties to the ultimate beneficial ownership (UBO) disclosure requirements in Ukraine:

  • All legal entities are required to submit updated information on UBO, which should include ownership structure, by 11 October 2021.
  • From the beginning of 2022, each legal entity will have an obligation to confirm UBO information on an annual basis and submit ownership structure within 14 calendar days from the date of its incorporation.
  • In case of changes of the UBO and/or ownership structure, the legal entity has an obligation to make a filing within 30 business days of the date of the respective change.

Non-compliance with the new regulation is an administrative offence sanctioned by a fine of UAH 17,000 to UAH 51,000 personally against the director of the company or the person entitled to act on behalf of the company (its executive body).