Ordinance no. 233/2018 on the Legal Framework of the Central Register of Effective Beneficiaries ("RCBE") was published, regulating the provisions of Law 89/2017, of 21 August, which also approved and strengthened the fight against money laundering and terrorist financing.

Reinforcing the transposition of AMLD 4, this Ordinance essentially, but still in an incomplete manner, regulates the practical implementation of the rules of the RCBE regime, particularly as regards deadlines, forms, reporting obligations and access to information.

In view of the specifications of the Ordinance, special attention should be paid to the respective sanctioning regime, which is particularly severe, and to its fiscal implications.

On 28 June 2019, Ordinance 200/2019 was published, revoking only Articles 13 and 17 of Ordinance 233/2018, which, in this sense, extended the reporting periods of the Central Registry of the Effective Beneficiary.