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EU continues its waltz with the fifth anti-money laundering directive


As of 10 January 2020, every EU member state must have implemented a public UBO register. Through this registration, anyone can look up the ultimate beneficiaries of entities established in their own EU member state. This obligation follows from the fifth anti-money laundering directive (AMLD5), which came into force on 9 July 2018.

This article also includes an overview of the implementation status of the UBO register in 16 EU and EER member states.

The fight against terrorist financing and money laundering is a major global challenge. It requires action and sound international cooperation, also between EU Member States. The registration of UBOs serves to identify the private individuals behind entities. In the recent tightening of this registration obligation, the EU Parliament has disregarded the question of how this relates to the privacy of those who are registered. Various EU parliamentarians indicate that they have 'the idea' or 'the feeling' that this is an effective and necessary means, but this is not substantiated.

What does this mean for you?

If you 'ultimately' have more than 25% interest in an entity such as a private limited company, the following will be publicly available: your (i) name, (ii) month and year of birth, (iii) place of residence, (iv) nationality and (v) the nature and extent of your interest. 'Ultimately' means that it does not matter whether you are a direct shareholder or whether you hold the interest through other entities such as a holding company. Neither does it matter whether it concerns ownership or mere power of control, both types of interest count and both can lead to a UBO qualification.

From 10 January 2020, the UBO registration must be operational in all EU member states. From 10 March 2020, the mandatory trust register, which is also part of the amendment of the fifth anti-money laundering directive, must be operational in all EU member states.

Here you find an overview of the implementation status of the UBO registration in 16 EU and EER member states.

Changes in UBO registration resulting from AMLD5

The fifth anti-money laundering directive has been tightened on several points compared to the fourth anti-money laundering directive (AMLD4). The most important changes are the following:

  • Public access to the UBO register is compulsory. Everyone should be allowed access to the register.
  • The separate trust register is only accessible to third parties with a legitimate interest.
  • Service providers that have to identify their customers (such as insurers, banks, tax advisers, accountants and notaries) are obliged to report any inaccuracies in the UBO registration.
  • All UBO registers in the EU will be linked as of 10 March 2021.

EU member states have 18 months after publication to implement these stricter provisions. In addition, the publication of the fifth anti-money laundering directive also granted a postponement for the implementation of the UBO register. This deadline was planned for 26 June 2017 on the basis of AMLD4, but is now, as a result of AMLD5, planned for 10 January 2020 at the latest.

More information on the UBO register?

Please refer to our three previous publications:


DIRECTIVE (EU) 2018/843 OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL of 30 May 2018 amending Directive (EU) 2015/849 on the prevention of the use of the financial system for the purposes of money laundering or terrorist financing, and amending Directives 2009/138/EC and 2013/36/EU.

Contact us

Rob Janssen

Rob Janssen

Partner, PwC Netherlands

Tel: +31 (0)88 792 14 41

Niels Govers

Niels Govers

Partner Family Business, PwC Netherlands

Tel: +31 (0)62 906 82 17

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