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In connection with a recent bulletin* of the Federal Service for Financial Monitoring (Rosfinmonitoring), legal entities are reminded that with effect from 21 December 2016 they are required to keep and disclose their beneficial ownership information to the competent Russian authorities in accordance with the amended Federal Law “On Combating Money Laundering and Financing of Terrorism”* (the “Law”). We reported on this obligation in a previous Alert.
Beneficial owners are individuals who own, directly or indirectly (through third parties), more than 25% of shares in a company or have the ability to control its actions.
As required by the Law, legal entities must:
Failure to comply with the requirements above may result in an administrative fine of up to RUB 40,000 (EUR 667) being imposed on the company’s officials and/or RUB 500,000 (EUR 8,333) on the company itself.
The above requirement to keep and disclose beneficial ownership information must be met by all legal entities, save for:
If, having taken all reasonable efforts, a company fails to identify its beneficial owners, it must provide the requesting competent authority with information on the measures it has taken, including relevant requests to and responses from its founders.
* In Russian