On April 6, 2018, the Draft 2018 Decree implementing the Wwft (hereinafter: the draft Decree), accompanying the Money Laundering and Terrorist Financing Prevention Act (Wet ter voorkoming van witwassen en financieren van terrorisme; hereinafter: Wwft), was published. The draft Decree includes an elaboration of the concept of UBO (Ultimate Beneficial Owner). Although the draft Decree specifically refers to a further elaboration of the Wwft, it is also relevant for the pending UBO register. The Explanatory Memorandum accompanying the draft Decree explicitly states that the UBO concept in the draft Decree will also apply for the purposes of defining UBO for the UBO register. The bill to implement the UBO register is expected before the summer. It will also include for which entities UBO information must be registered.
More information about this can be found in our separate memorandum on this.