Legal alert no. 46

Legal Alert no. 46- Law no. 89/2017, dated from August 21st Immediate implications of the entry into force of the CRBO

Yesterday, November 21st, Law no. 89/2017, dated from August 21st, which approved the Juridical Regime of the Central Register of the Beneficial Owner (“CRBO”) and proceeded to a whole series of other legislative amendments, entered into force.

As we informed in our newsletter no. 6 and in the Legal Alert no. 39, this law imposes a number of obligations for the entities covered by the CRBO and respective members, establishing relevant consequences to their the non-compliance.

Even though the regulation of the CRBO has not yet been published, from November 21st  it is mandatory to:

  1. Identify the beneficial owners in the commercial companies’/incorporation documents and/or in documents of incorporation of other entities that are subject to the CRBO;
  2. Maintain an actualized internal registry of the identification elements of the partners and beneficial owners of the company/other entities subject to the CRBO;
  3. Present a list of all the company’s partners with the respective identification elements, regarding to each amendment of the company’s articles of association and/or by-laws before the commercial registry;
  4. Register the incorporation, update/amendment or extinction of the trust regardless its duration period ;
  5. Indicate in all notarial, procedural and other acts containing facts that are subject to registry, all the cases in which the payment of an amount is in question, specifying the moment in which the payment occurred and the payment mean that was used.

To access the full version of Law no. 89/2017, dated the 21st of, please go to:

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