From the 15th March 2018, all types of companies, cooperatives, non-investment funds, nonprofit organizations, foundations and purpose associations of property without legal personality in terms of amendment of the Law on protection against the legalisation of crime proceeds and Terrorist financing to identify the final user of the benefits-the natural person who manages the entity or benefits from his/her activities. Exceptions are only public bodies. So far, this obligation was mainly related to companies enrolled in the Register of public sector partners, but from now on almost every company. Data on the end user benefits must be kept and updated. After the termination of the status of a natural person as the final user of the benefits, the company is obliged to keep the data for 5 For violation of obligations, companies are at a fine of up to EUR 200 000.

Together with the obligation to identify the final user comes also the obligation to enroll a natural person into the relevant registry. The registration will be free of charge and can be done using a separate form without the need to submit any documents. Data entered in the register will not be accessible to the public, only a person with a legitimate interest, for example, can request access. Investigative journalist.

Companies that arose 31. October 2018 or before that date, its end user benefits must register from 01. November 2018 to 31 December. December 2019. Conversely, companies that arise after that date will be obliged to register the natural person already when registering the company in the Register.

Given the complicated definition of the end-user of benefits and oftentimes the complex ownership and management structure of a legal person, it is not easy to correctly identify the end user of benefits, and we therefore recommend contacting our lawyer Office and avoid the fines that threaten your societies.