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The 4th Directive - Further Updates

  • Europe
  • Corporate secretarial services


As an update on the Fourth EU Money Laundering Directive (RL 2015/849) , please find below an outline of the new requirements in several more jurisdictions:


Denmark - All Danish private limited companies (ApS) and public limited companies (A/S) must report their beneficial ownership to the Danish Business Authority by 1 December 2017. If a company’s ultimate beneficial owner is listed on the stock exchange, there will be no beneficial owners, but this information must still be registered with the Danish Business Authority. A chart of the beneficial ownership should also be provided as documentation. Danish branches are not required to report their beneficial ownership.


Iceland & Norway – The directive is now under scrutiny by EEA EFTA. It has not yet been incorporated into the EEA Agreement and the ongoing legislative work is still in the preparatory stage - the draft law proposal is expected to be submitted in the first half of 2018.


Lithuania – The requirement to register beneficial ownership has been implemented through the already existing Information System of Participants in Legal Entities (JADIS), administered by the State Enterprise Centre of Registers - no new registry has been set up. Shareholders’ information must be provided to JADIS only when there is a change. A new extract from the companies register (if the Shareholder is a legal entity) or the passport copy (if the Shareholder is a natural person) should be submitted within 5 days of the change.


Poland - Significant provisions of the new Act on anti-money laundering and anti-terrorist financing, which will implement the directive, are still being discussed in the Polish parliament. The current Polish Act requires Polish entities to maintain the register of transactions which includes beneficial owners, however this requirement will be more extensive when the directive is implemented.


If you require any assistance with establishing the register, our legal teams are more than happy to assist and to provide further information on the new requirements in their region. If you have any questions regarding the directive, please contact Calypso Ranshaw ( and continue to check back here for further updates.