In earlier articles on our website, we already informed you about the register of ultimate beneficial owners, also known as the UBO register.
This register was set up as a central register managed by the Ministry of Finance and is online as of 28 September 2018.
All companies incorporated in Belgium must comply with the obligations relating to the UBO register.
This also includes companies without legal personality, such as partnerships, but also all (international) non-profit organisations, Belgian foundations, trusts and entities similar to trust or fiducie.
Initially, the registration in the UBO register had to take place before 30 November 2018, but this deadline was postponed by the Ministry of Finance until 31 March 2019.
And again the Ministry of Finance reports that an additional term will be granted until 30 September 2019.
It is crucial to take the necessary measures well in time, to collect the correct data about the right persons and to have them registered in the UBO register, taking into account the severity of the sanctions.
It is also important to draft and implement procedures within your organisation to collect and adapt the details of your final beneficiary owners, and to update the UBO register within one month after such change, as well as to work out a way in which the documents that prove that the information you provided are sufficient, accurate and up-to-date.
The Ministry of Finance provides a FAQ list on its website, that soon will be supplemented to give more clarifications.
We will keep you informed and it goes without saying that we are always ready to answer your questions in this area and to assist you with the registration.