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beneficial owner registration

We will represent you the new changes regarding the beneficial owner registration. In any case when a new law is adopted, the first thing that is noticed is its implementation in practice and the problems that practice will bring. As a result, the recently adopted laws are subject to periodic changes in order to eliminate the problems mentioned above.

The same can be said for DCM No. 1088 approved pursuant to the law No. 112 “On the register of beneficial owners” approved in 2020. This law is new in the field of law and as a result has suffered need for approval of some DCMs in its implementation.

Finally we are delighted to present you with the amendments of DCM No. 1088 as follows:

  1. Existing reporting entities, which result in “suspended” status in the commercial register, register the beneficial owner in the register of the beneficial owner, before the request for the change of their status in the commercial register. The change of the status of the existing reporting entities in the commercial register is performed after the verification that their beneficial owner is registered in the register of beneficial owners.

Simply said, the status of reporting entities can not be changed without first registering the beneficiary owner.

  1. In the case of initial registration and in the case of registration of changes in the data of the beneficial owners of reporting entities must be drafted within 90 (ninety) calendar days from the date of initial registration of reporting entities in the relevant registers.
  • Documentation certifying the unique identification number and name of the reporting entity, as well as the date of registration of the entity in the relevant register
  • Documentation of the competent registering authority, certifying that the registered beneficial owner is the owner of 25 (twenty five)% or more of the shares / quotas of the capital, voting rights or ownership interests, if it does not contain the date of determination as beneficial owner, another document containing this data must be filed;

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