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1 July 2021

New requirements on disclosure of ultimate beneficial owners by Ukrainian companies

Ukraine’s new AML Law, which took effect on 28 April 2020, introduced stricter and more sophisticated requirements to the disclosure of ultimate beneficial owners of Ukrainian companies.

Recently passed secondary legislation aimed at implementing the above requirements of the AML Law came as an unpleasant surprise: it introduced excessive disclosure requirements making full compliance with those for most of international groups rather challenging.

First deadline for disclosure is 11 October 2021.

Please refer to the attached file for a brief overview of the requirements and legal implications of non-compliance.

If you have any questions, please contact Oleksandr Nikolaichyk and Vladimir Sayenko.

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