We would like to bring to your attention the recent announcement by the Department of the Registrar of Companies and Intellectual Property regarding the annual requirement for entities registered under the Companies Law, Cap. 113, to confirm the information of their Ultimate Beneficial Owners (UBOs).

Annual Confirmation Requirement:

All entities incorporated or registered under the Companies Law, Cap. 113, including European Companies (SE) and Partnerships, are required to confirm their UBO details annually. This year’s confirmation period will run from 1st October 2024 to 31st December 2024 and will be conducted through the Beneficial Owners Registry System.

Who Needs to Comply:

• Companies incorporated or registered under the Companies Law, Cap. 113.
• European Public Limited Liability Companies (SE).
• Partnerships and Cooperatives.
• All other entities registered in Cyprus.

Steps for Confirmation:

1. Review and Confirm: Confirm the details of your UBOs, senior management officers, or due diligence as applicable, through the electronic system accessible only to entities registered in the Government Gateway Portal (Ariadni).
2. Update Information (if applicable): If there are any changes or initial entries to be made, they should be performed first, followed by the confirmation of details during the confirmation period.
3. Avoid Penalties: Ensure that the confirmation is completed within the stipulated period to avoid monetary charges and penalties.

Penalties for Non-Compliance:

Failure to confirm the information by 31st December 2024 will result in penalties as follows:

• A monetary charge of €200 on the first day of non-compliance.
• A further charge of €100 for each day of continued non-compliance, up to a maximum total charge of €20,000.
• Each officer or partner of the non-compliant entity will also be held accountable, unless due diligence can be demonstrated as per the provisions of N.188(I)/2007 and the amended Directive P.I. 112/2021.

What Actions Should You Take Now?

1. Verify Your Records: Ensure that the details registered in the system are accurate and up-to-date.
2. Notify Us of Any Changes: If there have been changes to the UBOs or other relevant information, inform us as soon as possible so we can take the necessary actions on your behalf.
3. Submit Confirmation by the Deadline: Complete the annual confirmation no later than 31st December 2024.

How Can We Assist?

We can assist you with the update and confirmation of your UBO details on the Beneficial Owners Registry. Our services include verifying existing information, updating the UBO registry where changes have occurred, and ensuring compliance with the annual confirmation requirement. This will help your entity avoid any potential penalties for non-compliance.

If you are our client, you will receive a dedicated email with specific instructions on how to proceed, along with detailed information on how we can assist you throughout the process to ensure seamless compliance.