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Thoughts

USA implements UBO regulation

March 2021

2 March 2021 - As of 1 January, 2021 the US authorities implemented Corporate Transparency Act (CTA) establishing beneficial ownership reporting requirements.

Key points to note:

  • The registration applies to all types of entities, except for (i) publicly traded companies, (ii) companies operating under governmental schemes and (iii) entities that fulfil a number of other conditions;
  • Any individual holding 25 % or more of ownership interest fall within the scope of UBO;
  • In the event of non-compliance, companies could be penalised 500 USD per day or even lead to criminal liability;
  • The due date for the registration of UBO and the procedure are expected to be clarified by 1 January, 2022.

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