Ukraine | New responsibilities for legal entities in connection with the latest anti-money laundering rules

With the entry into force on April 28, 2020 of the Law of Ukraine “On the Prevention and Counteraction to the Legalization (Laundering) of the Proceeds from Crime or Terrorism Financing, as well as Financing the Proliferation of Weapons of Mass Destruction” (hereinafter – the “Law”), the ultimate beneficial owners (hereinafter – the “UBO”) of legal entities are under special state control. The Law stipulates that the information about the UBO must be contained in the unified state register.

All Ukrainian companies shall submit information on the UBO and the ownership structure to the state registrar within 3 months from the date on which a legal act establishing the form and content of the ownership structure takes effect (such legal act has not been adopted by the competent authorities yet).

The companies need to provide the state registrar with the following documents:

  • the ownership structure completed according to the approved form
  • an extract from the foreign companies/trade registers regarding the company’s participants which are foreign legal entities
  • a notarized copy of the document certifying the person of the UBO

The documents confirming the UBO of the legal entities should also be provided to the state registrar in the following cases:

  • annually within 14 calendar days starting from the following year from the date of the state registration of the legal entity
  • in case of any changes of the company data reflected in the unified state register
  • in case of registration of a new legal entity in Ukraine.

To submit this information to the state registrar, the Ministry of Justice of Ukraine has approved new application forms, including a statement on confirmation of information on the UBO.

Please, note that the failure to submit or late submission to the state registrar of the information on the UBO or the UBO’s absence, as well as the documents confirming the information on the UBO, will be punishable by a fine of UAH 17,000 to UAH 51,000 personally against the director of the company or the person entitled to act on behalf of the company (its executive body).


If you would like to have more information on the new legal requirements for UBO disclosure as well as regulation of financial monitoring in Ukraine, please do not hesitate to contact us. Legal experts of SCHNEIDER GROUP in Ukraine will be ready to advise you on peculiarities of the current Ukrainian legislation in this regard.

Contact us

Artem Barinov
Associate Director, Legal & Tax, ADIT
+380 / 44 / 490 55 28

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