The implementation of the UBO-register, containing information on “Ultimate Beneficial Owners” of companies and other legal entities is one of the measures included in the 4th EU Anti-Money Laundering Directive (AMLD 4). On basis of AMLD 4, Member States had until 26 June 2017 to implement a UBO-register.
Hardly a year after the implementation of AMLD 4, the European Parliament adopted AMLD 5, which includes amendments to the UBO-register contained in AMLD 4. Under AMLD 5, Member States should implement the UBO-register for legal entities within 18 months - and for trusts within 20 months - after the new Directive enters into force.
On basis of the new implementation periods contained in AMLD5, the Dutch government has announced to send the legislative proposal for the implementation of the UBO-register for companies and other legal entities to Parliament in the beginning of 2019. It is expected that the UBO register will not be implemented before 2020.