Compliance Deadline For Dutch UBO Register Approaches

The Netherlands is gearing up for compliance with its new Ultimate Beneficial Owner ("UBO") register in late September, following the recent adoption of implementation legislation by the Dutch Senate. The drive by the European Union ("EU") for member states to introduce such measures, in accordance with international anti-money laundering and counter-terrorism financing best practices, will require newly formed entities to provide UBO information to the trade register operated by the Dutch Chamber of Commerce from 27 September 2020.

Entities already in existence will be afforded 18 months from the enactment date to comply and can expect to receive a letter outlining their responsibilities under the new law. These will include an obligation, which began on 8 July 2020 for entities in scope of the legislation, to collect and store UBO information. Similarly, foundations, including the Stichting, are now required to record any beneficiaries of less than 25% of the