Effective July 11, 2021 Regulations on the Form and Content of the Ownership Structure (approved by Order of the Ministry of Finance No. 163 dated March 19, 2021, published in the newspaper “Uriadovyi Courier” dated June 11, 2021).

The ownership structure is an official document that is provided to the state registrar to establish the ultimate beneficial owner of a legal entity without fail.

It is prepared in any form and in the form of a schematic image. The ownership structure shows all persons who directly or indirectly own a legal entity independently or jointly with other persons. In the ownership structure, it is necessary to indicate the amount of participation of each of the owners, as well as indicate persons who, regardless of formal ownership, can influence the management or activities of the legal entity significantly. In addition, it is necessary to indicate the description of the implementation and the nature of the decisive influence of the final beneficial owner on the activities of the legal entity.

If information about the ultimate beneficial owner of a legal entity is not clearly tracked according to the Unified State Register, official documents confirming the possibility of such a decisive influence must also be attached to the schematic image.

Samples of drawing up a schematic image of the ownership structure are published on the official website of the Ministry of Finance.

The Law of Ukraine “On Preventing and Counteracting to Legalization (Laundering) of the Proceeds from Crime, Terrorist Financing and Financing Proliferation of Weapons of Mass Destruction” No. 361-IX dated December 6, 2019 obliged all previously registered legal entities to submit to the state registrar information about the ultimate beneficial owner (hereinafter referred to as the UBO) and the ownership structure within 3 months from the date of entry into force of the regulatory legal act, which will approve the form and content of the ownership structure.

This Law also required maintaining up-to-date information about the UBO and ownership structure, updating it and notifying the state registrar of changes within 30 business days from the date of their occurrence, and submitting documents confirming these changes to the state registrar.

Submission of information about the UBO of a legal entity is expected for the first time in 2021 after the adoption of a regulatory legal act that approved the form and content of the legal entity’s ownership structure.

The Ministry of Justice will check the facts of non-submission of information about the UBO.