Obligation to Maintain an Ultimate Beneficiary Owners Register in Finland

The Act on Combating Money Laundering and Financing of Terrorism, which implements the EU’s 4th Anti-Money Laundering Directive and the EU Regulation on Payer Information Accompanying Transfers of Funds was approved in Finland on 28 June 2017.

Following the expiry of the transition period on 1 January 2019, legal entities have since then had an obligation to maintain information on their ultimate beneficiary owners. As ultimate beneficiary owners are considered individuals that own, directly or indirectly, more than 25 % of the shares in a company or another corresponding share in another type of legal entity or that through ownership or otherwise have more than 25 % of the votes in a legal entity subject to the Finnish UBO rules.

Indirect ownership refers to a situation where a legal entity owns more than 25 % of the shares or has more than 25 % of the votes in the legal entity subject to scrutiny or is entitled to appoint or dismiss a majority of its board members.

As an ultimate beneficiary owner may also considered another individual that otherwise in fact uses decision-making power in the legal entity. In case the ultimate beneficiary owners of a legal entity cannot be identified, the company’s board of directors or managing director shall be considered the entity’s ultimate beneficiary owners.

The board of directors or a corresponding corporate body shall maintain a register on the entity’s ultimate beneficiary owners. The register shall contain each ultimate beneficiary owners name, date of birth, citizenship, country of residence, and the ownership share. The UBO register shall be maintained up to date.

Each legal entity is required to notify the Finnish Patent and Registration Office of its ultimate beneficiary owners no later than 1 July 2020, after which any changes in the ultimate beneficiary owners shall be submitted to the Patent and Registration Office without undue delay.

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