Law n. º 89/2017, published on August 21st, implemented Directive 2015/849 on the prevention of money laundering and terrorist financing, having created the legal regime of the Central Registry for the Beneficial Owner (CRBO).

According to article 1 of such Law, the CRBO consists of a database containing sufficient, accurate and up-to-date information about the persons who own or effectively control the entities subject to this legal regime.

These regime covers all associations, cooperatives, foundations, civil and commercial corporations, as well as any other collective entities that carry on an activity or legal transaction for which a tax identification number (NIF) is required, as well as the branches of multinational corporations or foreign law bodies that are active in Portugal. Trusts and branches of financial companies registered in Madeira’s free trade zone are also subject to this regime.

As a concept, the beneficial owner is the person who owns or effectively controls, the above mentioned entities.

Beneficial Owners are thus required to provide information such as: i) the relevant entity; (ii) the Beneficial Owner; iii) the signatory (who may either be the legal representative of the covered entity, a lawyer or certified accountant, among other representatives).

The above-mentioned obligation is completed through the submission of an electronic form, as approved by Ministerial Ordinance n. º 233/2018. Said ordinance also includes important instructions on the regime.

Some of the information provided under this regime will be publicly available on the Ministry of Justice’s website (yet to be determined), allowing interested parties to access said information through authentication in the mentioned website. The data that is going to be publicly available includes the identification number, legal name and nature, headquarters address, activity tax code and legal entity identifier. As for the Beneficial Owner, only name, month and year of birth, nationality, country of residence and economic interest are made available to the public.

Non compliance with this regime makes the entity not entitled to pay dividends, conclude contracts with public bodies, issue bonds or any other kind of debt instrument, benefit from European Structural Funds, and to take part in any kind of deal involving real estate ownership transfer.

In compliance with the above rules, starting January 1st, the entities covered by the regime must submit the initial declaration until April 30th, 2019, when subject to commercial registry, or June 30th, for the remaining entities.

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José Calejo Guerra

António Branco

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