Launch of systematic checks on compliance with the rules relating to the Luxembourg Register of Beneficial Owners

Key takeaways from the RBO framework

As a reminder, all entities registered with the Luxembourg Trade and Companies Register (RCS) are required to obtain and hold adequate, accurate, and up-to-date information on their beneficial owners and to file such information electronically with the RBO. They are also expected to ensure that this information remains up to date. 

Applicable sanctions

Breaches of the RBO legislation expose the relevant entities to fines ranging from EUR1,250 to EUR1.25 million. In addition, the press release states that entities whose registered office or declared address is untraceable may be subject to dissolution without liquidation proceedings or, as the case may be, judicial liquidation.

Recommended actions

In light of the imminence of these checks, we recommend that the relevant entities carry out the following verifications without delay:  

• Verify and update the information filed with the RBO, if necessary.  
• Ensure that information relating to their beneficial owners, together with all supporting documentation, is kept at the entity's registered office.  
• Ensure that clear protocols are in place to monitor and respond to communication received from the Grand Ducal Police.  

Our AML/CFT team is at your disposal to assist you with these compliance steps if needed.