Luxembourg Register of Beneficial Owners: publication of illustrative examples on the identification of the beneficial owner
On 9 August 2019, ALCO, ALFI, LPEA and LuxReal (the “Task Force”) published a document setting out illustrative examples regarding the identification of the beneficial owner(s) (“BOs”) within investment funds.
This document is only accessible by a limited audience: contact us for an analysis of the examples related to your situation. The document provides examples on the approach to identify the BOs in investment funds, depending on the distribution strategy used. Examples are provided with regards to widely distributed funds, dedicated funds, exchange traded funds, funds with one or more main intermediaries, funds of funds and funds with limited distribution.
The Task Force however reminds market participants that the BOs of each fund must be assessed on a case by case basis and that these examples are not exhaustive or exclusive.
What is the timeline?
Existing Luxembourg entities have until 1 September 2019 (at the latest!) to compile their internal file on BOs and to register the relevant information with the RBE (Registre des bénéficiaires effectifs) / RBO (Register of Beneficial Owners). Amendments to the BO related information should be filed within one month after the registered entity is aware or should be aware of such amendment.
How we can help
BENEFICIAL OWNERS HELPDESK
We offer a single helpdesk in order to answer your questions and have a suite of fixed price services to ensure that you shall comply with the new law.