Disclosure of Beneficial Owners

Starting from December 21, companies will be obliged to identify their beneficiaries, log and store documentarily information about them and update the information regularly (not less than once a year)*. If a company is unable to identify its beneficial owners because of a complicated structure, for example, it shall store documents confirming that attempts to identify them were taken. This information must be supplied at the request of the Federal Financial Monitoring Service of Russia, The Tax Authorities, The Central Bank of Russia and also must be disclosed in reporting.

Beneficiaries are understood to mean individuals who ultimately own directly or indirectly more than 25% of a legal entity or are able to exercise control over its activities.

Companies shall identify the following information on their beneficial owners: passport data, residential address or address of stay, migration card data and other information.

Failure to execute the duties regarding the above may be punishable by a fine in the amount of 30 000 – 40 000 rubles for officials and 100 000 – 500 000 rubles for companies**.

* art. 6.1 of the Federal law of 07.08.2001 “On combating legalization (laundering) of illegally gained income and financing of terrorism”

** art. 14.25.1 of Administrative Offences Code


Olga Semenova
Partner. Chief Operating Officer
Olga Vorobyeva
Head of the Legal Practice