Answer ... In Ukraine, there are both state and private registries that can assist in finding and confirming such information.
Access to individual state registries is generally public; but certain access restrictions are currently in place which, from the government’s point of view, are related to the current regime of martial law due to Russia’s armed aggression in Ukraine.
The Unified State Register of Legal Entities, Individual Entrepreneurs and Public Organisations is a public state register which contains the details of the ultimate beneficial owners of a business and similar details. In addition, there are private services that are synchronised with public services – for example, Opendatabot and Youcontrol also allow users to:
- identify the ultimate beneficial owners of a company;
- obtain information about court decisions, recoveries or the evaluation of a potential counterparty; and
- obtain certain analytical information collated these services.
In addition, separate registers maintained by state bodies provide opportunities for public access to information for citizens and companies. For example, the State Financial Monitoring Service maintains a database of the subjects of primary financial monitoring (business entities) and the supervision of relevant financial transactions, which has an internal (official) purpose.
Regarding ultimate beneficial owners, on 11 July 2021 the Regulation on the Form and Content of the Ownership Structure, approved by Order 163 of the Ministry of Finance of 19 March 2021, entered into force.
In accordance with this regulation and the norms of the AML Law, all legal entities in Ukraine that were registered as of 11 July 2021 had to submit information about their ultimate beneficial owners to the state registrar within 90 days. This term was subsequently extended to one year; and on the commencement of full-scale war in Ukraine, the term was extended indefinitely until the date of termination or cancellation of martial law in Ukraine.
Thus, legal entities must submit details of their own ownership structure, indicating the persons that:
- directly or indirectly own the company independently or jointly with other persons; or
- regardless of formal ownership, have the possibility to exert significant influence on the management or activity of the legal entity.
The notarised passports of the ultimate beneficial owners must also be submitted to the state registrar.
In addition, the State Financial Monitoring Service maintains a list of persons associated with the conduct of terrorist activities or against whom international sanctions have been applied.