On October 31, 2021, the provisions amending the Act of March 1, 2018 on Anti-Money Laundering and Financing of Terrorism (the “AML Act”) entered into force.
If the beneficial owner or a member of the board or a partner authorized to represent a Polish company has a citizenship that has not been reported to the Central Register of Beneficial Owners, the relevant company shall report such information to the CRBR.
Therefore, at the moment, the following data of the beneficial owner, member of the company board or shareholder entitled to represent the company should be indicated:
- first and last name,
- any citizenship held,
- PESEL number or date of birth,
- information on the size and nature of the shares or entitlement held by the beneficial owners.
The above change is to be effective from April 30, 2022. However, the Ministry of Finance has not prepared in a practical way for these changes and until April 29, 2022 (also due to the interruption of the operation of the governmental servers https://www.gov.pl/web/finanse/komunikat-nr-44-dotyczacy-przerwy-w-dostepnosci-uslug-w-systemie-crbr-od-dnia-28-kwietnia-2022-r-do-dnia-29-kwietnia-2022-r) no appropriate form has been made available in which it would be possible to enter more than one citizenship held.
If in your case a reported beneficial owner, member of a board or partner entitled to represent the company has more than one citizenship and you would like to make such a declaration, we can assist you.
If you have any questions, please contact us.