Central Ultimate Beneficial Owner Register

The Ministry of Finance practically sets priorities for proper recording of the data of the legal entities liable in the Central Register in order to achieve transparency of corporate structures and to prevent their misuse for the purposes of money laundering and terrorist financing.

In the context of implementation of Law 4557/2018 (Government Gazette A 139 / 30-07-2018) on Preventing and Combating Money Laundering and Terrorist Financing, Greece has incorporated the relevant Directive (EU) 2015/849 into its internal legal system, and pursuant to Decision 67343ΕΞ2019/19-06-2019 of the Minister of Finance (B 2443/20-06-2019), as amended by article 73900 ΕΞ 2019/02.07.2019, it has complied with the procedure of registration of the data of the Central Ultimate Beneficial Owner Register kept on the website of the General Secretariat for Information Systems.

In particular:

According to the aforementioned law, any legal entities headquartered or carrying on business in Greece are required to register electronically their ultimate beneficial owners.

The obligated for registration of the above data, as defined in article 2 of the mentioned decision, are commercial companies, including subsidiaries or branches of domestic or foreign companies with a ultimate beneficiary listed company in Greece or abroad, shipping companies, civil professional companies, non-profit entities, trusts, cooperatives, companies are in bankruptcy, liquidation, while listed companies in a regulated market or Multilateral Trading Facility operating in Greece are automatically registered in the Central Register of ultimate beneficial owners, by connecting the Central Securities Depository with the General Secretariat for Information Systems.

The beneficial owners are members of the Board of Directors, CEO, Executive Director, Administrator, General Manager, Director, other person directly or indirectly authorized by law or by private will or by court order for management, administration or representation of company, partner, shareholder, persons with other status.

In the event that a legal entity is incorporated during or after 16/09/2019 until 29/11/2019, the details of its ultimate beneficial owners shall be registered within 60 days of its incorporation.

The registration of the data is performed on the electronic platform of the Central Ultimate Beneficial Owner Register on the website of the General Secretariat for Information Systems within the following deadlines:

  1. Group A which includes, inter alia Civil Professionals and Shipping Companies: 16/9/2019-14/10/2019
  2. Group B which includes, inter alia, Private Companies, Non-Profit Legal Entities, Cooperatives, Legal Entities of Public Law and Single-Member Société Anonyme: 30/9/2019-1/11/2019
  3. Group C which includes the other commercial companies (general partnership, limited partnership,limited liability company, Société Anonyme): 14/10/2019-29/11/2019. Relevant annex with the grouping of the obliged for registration is attached.

The competent audit authorities shall have complete and unlimited access to the data, while legal and natural persons may also have access to obtain information upon payment of the prescribed fee.

In case of non-compliance of the obliged persons with the registration of the data, a freezing to provide a tax clearance certificate and an imposition of fine of 10.000 euros is foreseen. In the event of a repeat infringement, the fine is doubled.

By decision of the General Secretary of Public Administration for Information Systems, it was decided to suspend the information system «Central Ultimate Beneficial Owner Register» of General Directorate for Economic Policy of the Ministry of Finance for forty (40) calendar days, i.e. from 22/11/2019 to 19/01/2020. Consequently, the deadlines for the submission of the data of the ultimate beneficial owners are suspended, thereby giving the obliged legal entities an additional time to prepare the Special Register to be kept at their registered office (article 20 of Law 4557/2018) and to register it with the Central Ultimate Beneficial Owner Register of the Ministry of Finance.