Central Register Of Beneficial Owners – severe penalties for failure to make an entry

On 13 October 2019, the Central Register of Beneficial Owners will start to operate in Poland to which every operating company will have to enter information on its beneficial owner, subject to penalty for non-compliance of up to PLN 1 million.

An obligation to create the Central Register of Beneficial Owners results from the implementation of Directive (EU) 2015/849 of the European Parliament and of the Council of 20 May 2015 on the prevention of the use of the financial system for the purposes of money laundering or terrorist financing.

What information should be reported to the CRBO?

The Central Register of Beneficial Owners, apart from the basic corporate data, will include identification data of beneficial owner and member of governing body or shareholder authorized to represent the company, such as:

• name and surname,
• nationality,
• country of residence,
• PESEL number or date of birth,
• information on the nature and extent of the beneficial interest held.

How to file a notification?

Notification to the Central Register of Beneficial Owners may be made via a dedicated website of the register and will require an electronic signature or signature confirmed by ePUAP trusted profile. The register will be non-confidential and available to the public free-of-charge.

Failure to provide information to the Central Register of Beneficial Owners is threatened with a financial penalty of up to PLN 1,000,000.00, whereas for providing untrue data on beneficial owner, a reporting entity may be held liable for perjury.

How can we help?

We may assist you in the notification procedure to the CRBO. We will help you to determine which natural persons should be reported to the Central Register of Beneficial Owners.