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The Beneficial Owner Central Registry (Deadlines: 30 April and 30 June 2019)


The Ordinance No. 233/2018, which regulates the Legal Regime of the Central Registry of Effective Beneficiaries ("RCBE"), was published, specifying and supplementing the provisions of Law 89/2017 of August 21, which approved the respective regime and reinforcing elements contained in Law 83/2017 of 18 August, which regulated the fight against money laundering and terrorist financing. Reinforcing the transposition of AMLD 4, this Ordinance essentially, but still in an incomplete way, regulates the practical implementation of the rules of the RCBE regime, namely regarding deadlines, forms, declaratory obligations and access to information. In view of the specifications of the Ordinance, a special attention should be given to the respective sanctions regime, particularly severe, and fiscal implications.