In a noteworthy development, the Department of the Registrar of Companies and Intellectual Property has officially communicated the phased implementation of the Final Solution for the electronic system of the Register of Beneficial Owners. This strategic initiative, set to commence on 14 November 2023, seeks to bolster transparency and accuracy in the disclosure of beneficial ownership information for Companies under Companies Law, Cap. 113, European Companies (SE), and Partnerships.

I. Period A (14 November 2023 to 31 December 2023):

During Period A, a pivotal phase in this implementation process, Entities encompassing Companies, European Companies (SE), and Partnerships, along with their respective Officers/Partners, are mandated to scrutinize the information previously submitted during the Interim Solution. In instances where changes have occurred since the interim period, entities are obligated to promptly update the information. Importantly, this period is characterized by a lenient approach, with no penalties imposed on entities during this initial phase.

II. Period B (1 January 2024 to 29 February 2024):

The transition to Period B, commencing on 1 January 2024, marks a critical juncture where penalties will be enforced for non-compliance. Entities and their Officers/Partners failing to verify or update information as required during Period A will incur penalties structured as follows:

A one-off penalty of two hundred euros (€200) on 1 January 2004.

An additional penalty of one hundred euros (€100) for each subsequent day of non-compliance, with a maximum capped penalty of twenty thousand euros (€20,000).

This period underscores the imperative for entities to proactively adhere to the prescribed timelines and procedures to circumvent the imposition of penalties and maintain compliance with the regulatory framework.

III. Period C (1 March 2024 onwards):

As of 1 March 2024, the Final Solution will be fully operational, ushering in a new era of enhanced compliance. The following key features will be integral to this phase:

Timely Updates: Entities and their Officers/Partners are duty-bound to expeditiously update any changes to the information previously reported with the Register within a strict timeframe of 14 days from the moment awareness of such changes arises.

Annual Verification: A cornerstone of the Final Solution, all Entities are compelled to undergo an annual verification process during the month of December. This mandatory process holds irrespective of whether any changes were submitted to the Register throughout the preceding year. Compliance with this annual verification is paramount to maintaining accurate and up-to-date beneficial ownership information.

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