In a follow-up to the creation of the Final Beneficiary Registry (FBR) in August, on September 30, 2020, the National Registry Office issued an informative circular addressed to companies and the private sector.
The circular indicates to all companies, and before the entry into force of the FBR, the necessity to update their basic information* in the Mercantile Registry and register all the deeds that imply changes in their basic information, such as any change in shareholders, participation or ownership structure, control, legal representatives and any other information related to changes in the administrative bodies (board of directors, administrators, etc.).
According to the communication, the objective is to update all company documentation and assure that inscriptions in the FBR coincide with the information filed in the Commercial Registry.
The circular invites companies to use the period before the entry into force of the FBR, i.e. now, to update their information and record the changes and modifications that the companies have incurred while bearing in mind that the data update process requires the registration of notarized documents, and is according to the request of duly accredited representatives of the company.
*Basic information includes all the information that must be contained in the articles of incorporation of commercial companies under the commercial code:
- Name, surname, and address of the grantors.
- Name and address of the company.
- Purpose of the company and its operations.
- The social capital: number, quality, and value of the shares.
- The person or persons representing the company.
- Any other relevant information.
Final beneficiary information includes all the data needed to identify fully the natural person who is the final beneficiary of a commercial company.