This decision of the Registrar follows the earlier preliminary ruling of the Court of Justice of the European Union (the “CJEU”) of 22 November 2022, which rendered the provision of the EU anti-money-laundering directive, pursuant to which Member States must ensure that the information of the beneficial ownership of corporate and other legal entities incorporated within their territory is accessible in all cases to any member of the general public, invalid. According to the CJEU, the general public’s access to the information of the beneficial owners constitutes a “serious interference with the fundamental rights to respect for private life and to the protection of personal data” enshrined in Articles 7 and 8 of the Charter of Fundamental Rights of the European Union. Lastly, in its announcement, the Registrar confirmed that the UBO information will continue to be provided to competent supervisory authorities and the obliged entities (e.g. financial institutions, law firms, auditors, fiduciary services providers etc.) provided that, in the case of obliged entities, a solemn declaration confirming that the information on the UBO Register is requested within the context of performing customer due diligence, is submitted.

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