Four Months to Disclose Legal Entity’s Ownership Structure


11 June 2021 saw the published form of disclosing the legal entity’s ownership structure approved by Order 163 of the Ministry of Finance of Ukraine dated 19.03.2021 (hereinafter – the Order) pursuant to Law of Ukraine No. 361-ІХ “On Prevention and Counteraction to Legalization (Laundering) of Proceeds of Crime or Financing of Terrorism and Proliferation of Weapons of Mass Destruction” dated 06.12.2019. New requirements to the disclosure of the legal entity`s ownership structure will apply from 11 July 2021. All legal entities incorporated in Ukraine must submit their ownership structures to the state registrar till 11 October 2021 in compliance with new requirements.

The Order says that the ownership structure shall be made in free form and always contain:

  • all persons owning a legal entity, whether directly or indirectly, independently or jointly with the other legal entities
  • the stake held by each of the shareholders
  • persons who, irrespective of the form of ownership, have a significant influence on the legal entity’s management or activities
  • the description and nature of the UBO’s decisive influence on the legal entity’s activities

The schematics of the ownership structure should be filed along with official documents (copies thereof) confirming the title to make a decisive influence on the legal entity’s management or activities.

N.B.! Failure to submit or delayed submission to the state registrar of the legal entity’s UBO details or relevant documents will result in the penalty imposed on the legal entity’s director and amounting to UAH 17,000 – 51,000 (approximately EUR 510 -1,530).

Moreover, the fulfillment of the disclosure obligation will be required to amend the legal entity’s profile in the Unified State Register of Legal Entities, Individual Entrepreneurs and Civic Organizations.