Transitional arrangement for UBO Register ended

New rules for Wwft institutions regarding the UBO register effective from August 1, 2024.

In the Parliamentary letter dated April 17, 2024, a new procedure for consulting information on Ultimate Beneficial Owners (“UBO”) information was announced for institutions subject to the Anti-Money Laundering Directive (“Wwft institutions”) that do not yet have a direct connection to the UBO register via the data service of the Dutch Chamber of Commerce (“KvK”). The existing transitional arrangement ended on August 1.

• As of August 1, 2024, Wwft institutions that do not yet use the KvK data service must request a certified extract from the UBO register from their clients. Clients can request this extract themselves from the KvK. This ends the old transitional arrangement, which allowed for a confirmation email from the KvK of the UBO registration or a screenshot of the UBO data. The Wwft institution does not need to request a certified extract from existing clients for whom it has already been established that a UBO is registered. This remains a transitional arrangement; once a Wwft institution is connected to the UBO registers, the legal obligation for these institutions to consult the UBO register themselves applies.

• Wwft institutions are required to report any discrepancies between the information from the UBO register and other information the institution has to the KvK. From October 1, 2024, this reporting obligation also applies if a Wwft institution receives a certified extract from the client. 

Wwft institutions can connect directly to the UBO register via the KvK data service. The Wwft institution then needs to request less information from its clients and maintains control over the client investigation, including the UBO check. All Wwft institutions must eventually regain direct access to the UBO register.