The National Bank Regulated the Procedure for Banks and Non-Bank Institutions to Report Discrepancies in Beneficiary Information.

12/11/2024

The National Bank has regulated the procedure for banks and non-bank institutions to report discrepancies between the information on ultimate beneficial owners (UBOs) and a client's ownership structure (hereinafter, "UBO and ownership structure discrepancies") in line with current legislative requirements. Amendments have been made to regulatory acts on financial monitoring.

The regulator explained that banks and non-bank financial institutions must notify the holder of the Unified State Register (USR)—the Ministry of Justice—upon identifying such discrepancies. Previously, these reports were sent to the State Financial Monitoring Service.

Specifically, the changes provide for:

  • a timeframe for banks and non-bank financial institutions to determine the presence or absence of UBO and ownership structure discrepancies;
  • detection of discrepancies and notification to the Ministry of Justice in accordance with its established procedures.

Banks and non-bank institutions will have a one-month transition period to align client questionnaires, relevant client lists, and discrepancy registers with these changes.

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