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Register of Beneficial Owners Update

Implementation of the final solution of the electronic system of the Register of Beneficial Owners

We would like to inform you that the Department of the Registrar of Companies and Intellectual Property (the “Department”) has recently announced the following final arrangements regarding the implementation of the electronic system of the Register of Beneficial Owners (the “BO Register”):

Period A - 14 November 2023 to 31 December 2023

  • All Companies registered as per Companies Law, Cap. 113, all European Companies (SE) and all Partnerships (the “Entities”) or their Officers/ Partners (as the case may be), are required to record/re-record the information regarding their Beneficial Owners, even if such information was recorded with the BO Register during the Interim Solution, or to update it if changes have occurred in the meantime
  • No penalties will be imposed during this period

Period B - 1 January 2024 to 29 February 2024

  • All Entities that did not record/re-record the information during period A will be able to do so
  • Penalties (see below) will apply

Period C - 1 March 2024 onwards

  • All changes to the information recorded in the BO Register for a specific Entity must be updated within 14 days from the time such Entity or its Officers/Partners become aware of the changes
  • All Entities are required to verify the information recorded in the BO Register annually, during the month of December.
  • The annual verification process is mandatory, irrespective of whether there were any changes to the information recorded in the BO Register during the year or not.
  • Penalties (see below) will apply.

 

Penalties for non-compliance

  • A corporate or other legal entity (and each of its officers) will incur a fine of €200 for non-compliance.
  • The fine may be accompanied by a daily penalty of €100 for each day of non-compliance, with a maximum charge of €20,000
  • Individual criminal prosecution may also apply.
  • Officers of a corporate or other legal entity will be exempt from such fines if they have exercised due diligence in adhering to the provisions of N.188(I)/2007 and Directive P.I. 112/2021, as amended, and the violation is not attributed to their actions, omissions, or negligence.

 

How can we help?

Please contact our team if you require our assistance in submitting the required information to the Register of Beneficial Owners or for any further clarifications:

Contacts:

 

 

Andreas Zachariades

Senior Manager, Outsourcing Services

andreas.zachariades@cy.gt.com

Arda Aynedjian

Senior Consultant, Regulatory Compliance and Funds Services

arda.aynedjian@cy.gt.com

Konstantina Karekla

Senior Associate, Outsourcing Services

konstantina.karekla@cy.gt.com