Dutch UBO register to come into force in January 2020

On 4 April 2019, the Dutch Minister of Finance (the Minister) submitted a legislative proposal for the introduction of an ultimate beneficial owner register (the UBO Register) in the Netherlands (the Proposal) to the Dutch Parliament. The Minister also, among other things, submitted the explanatory notes to the Proposal, as well as the advice from the Dutch Council of State (Raad van State) and the Dutch Data Protection Authority (Autoriteit Persoonsgegevens, the AP). The UBO Register is a register that will contain details on individuals that are ultimate beneficial owners (UBOs) of legal entities based in the Netherlands (UBOs of foreign entities active in the Netherlands will not be included in the UBO Register). All Member States, including the Netherlands, are required to introduce a UBO Register pursuant to the Fourth Anti-Money Laundering Directive (EU/2015/849) (Vierde anti-witwasrichtlijn, 4MLD). Under 4MLD, Member States had until 26 June 2017 to implement a UBO…

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