Compliance Consultancy
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UBO Register AML


What is the Ultimate Beneficiaries Owner - UBO Register ?

meaning of the ubo register 2019
The implementation of the use of the UBO register, or the register for beneficial owners, was implemented with the AMLD4 and transposed into national laws of Member States.

The origin of the global framework for tracing beneficiaries was a request from the G20 and other bodies like IMF, BIS, OECD, FSB, FATF, and UN. The objective is to enable safe data exchange, cross-referencing, and tracing and analysis, allowing secure cross-border financial transactions. The disclosure of the parties behind a transaction ensures transparency.


What is the UBO Register's added value?

To quote the Directive 2018/843 of the EU parliament and the EU Council of 30 May 2018, public access to beneficial ownership information allows greater scrutiny of information by the civil society, the press or organisations. The UBO information contributes to preserving trust in the integrity of business transactions and the financial system.

UBO registers will assist in combating the misuse of entities and legal arrangements for the purpose of money laundering or terrorist financing by helping investigations and through reputational effects, given that anyone who could enter into a transaction is aware of the identity of the beneficial owners.
It also facilitates the timely and efficient availability of information for financial institutions as well as authorities, including authorities of third countries involved in combating such offences.
The access to that information would also help investigations on money laundering, associated predicate offences and terrorist financing.
added value of ubo register



Who can access the UBO Register ?

The accessibility and disclosure to the general public of these extended registers has been adopted by the 5th AMLD where Member States should ensure that national registers of ultimate beneficial owners of companies and other legal entities are kept up-to-date with valid information and remain available for public consultation. Access to the UBO information for trusts is exempted.

It is critical to know the people behind the series of cross-border transactions between different companies or structures to combat money laundering and financing of terrorism.


What about the UBOs in Belgium ?

In Belgium the deadline for the submission of beneficial owners has already been extended twice. On 30th of September 2019 companies have to complete the register. As the deadline has been extended, do not hesitate to read the latest considerations on our article dedicated to updates and useful tips on the UBO register.

As a management company, we assist our customers in the submission process of your company shareholding structure. On first sight, the Belgian UBO will receive a confirmation of the percentage of his/her ownership.



Can we rely on the content in the UBO register for KYC processes ?

The Law provides for the obligation for companies, a(i)sbl and foundations to collect and hold adequate, accurate and current information on their beneficial owners and for the administrators to transmit this information within the month and by electronic means to the UBO register.

Inconsistency in the ownership can be verified through the register, and if the company is owned by other companies, the ownership chart is publicly available.

For financial institutions a redesign of the KYC processes is necessary. If the risk based approach already took into consideration these changes, then minor changes are required.


Is the net closing for the criminals ?

criminals money laundering ubo register exposure
Future will tell, but as mule accounts are a burden to trace people who pull strings in transactions, mule beneficial owners might also pop up. The question is how offenders will tackle the freezing of the companies and their assets by the government once detected.


We will use our knowledge to trace this as we did for Specially Designated Nationals and Blocked Persons and try to establish the links between the real and false UBO’s.

New investments in the use of blockchain technology where data tampering is impossible might bring a bright future for compliance processes.

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