On disclosure of UBO of Russian companies

On disclosure of UBO of Russian companies

07 February 2019

Let us draw your attentionthat Russian legal entities are obliged topossessinformation about their ultimate beneficial owners (hereinafter the «UBO») in accordance with para.1art. 6.1 of the Federal Law No. 115-FZ “On prevention the legalization (laundering) of proceeds of crime and financing of terrorism”.

On February 3, 2019 the Federal Tax Service (he-reinafter the «FTS») obtained possibility to officially send formal requests to Russian legal entities in order to obtain information about theirUBOs(Order of the FTS of Russia dated December 20, 2018 No. MMB-7-2/824@).

Upon the request from the FTS, the legal entity is obliged to provide information about its UBOs or to report on measures taken to obtain this information.

Violation of the above obligation is subject to the administrative fine: for the officials from 30 to 40 thousand rubles, for the legal entities - from 100 to 500 thousand rubles in accordance with art. 14.25.1 of the Russian Code of administrative offenses.

We would like to emphasize that it is very important for Russian business to obtaininformation about its UBOsin timefrom its participants/shareholders.ALRUD team would be pleased to assist you with all ne-cessary actions, if required.

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Practices: Corporate and M&A Private clients

Note: Please be aware that all information provided in this letter was taken from open sources. Neither ALRUD Law Firm, nor the author of this letter bear any liability for consequences of any decisions made in reliance upon this information.

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