Financial Crime World

Croatia Introduces Beneficial Ownership Transparency Amid Anti-Money Laundering Efforts

The Croatian government has taken a significant step in combating money laundering and terrorist financing by implementing the European Union’s anti-money laundering (AML) regulations. As of May 24, 2019, companies, branches of foreign companies, associations, foundations, and institutions are required to provide data on their beneficial owners.

Registration Obligation

The registration obligation applies to entities where the Republic of Croatia or local/regional unit of self-government is not the only founder. Institutions with the Republic of Croatia or local/ regional unit of self-government as the sole founder are exempt from this requirement. Companies listed on stock exchanges are also exempt, but they must provide information on their listing status and share ownership structure. Associations will obtain data on authorized representatives from the Public Information System (PIN).

Register of Beneficial Owners

The Register of Beneficial Owners is maintained by the Financial Agency (FINA). The Ordinance on the Register of Beneficial Owners prescribes the procedure and deadlines for providing data.

Data Requirements

Entities required to provide data must gather accurate, up-to-date, and adequate information on beneficial owners, including:

  • Name
  • Country of residence
  • Date of birth
  • Citizenship/citizenships
  • Identification number or type
  • Number, issuer, country, and validity date of the identification document

Data collection will be done on a case-by-case basis, especially in complex ownership structures.

Deadlines and Accessibility

The deadline for entering data into the Register is 30 days from the date of change. Most data will be publicly available, except for identification numbers and documents, which will be accessible only to competent state authorities.

Restrictions and Penalties

Access to beneficial owner data may be restricted if it poses a disproportionate risk or if the beneficial owner is a juvenile or has been deprived of their business capacity. In such cases, a legal entity or public body can request clarification and substantiation.

The prescribed penalties for non-compliance range from 5,000 to 350,000 Croatian kuna (approximately $700 to $47,000 USD) for legal entities and 5,000 to 75,000 Croatian kuna (approximately $700 to $10,000 USD) for responsible individuals.

Conclusion

The implementation of beneficial ownership transparency in Croatia is a significant step towards combating money laundering and terrorist financing. Our team of AML regulatory compliance experts is available to assist you with data collection, identification of beneficial owners, submission of applications, and requests for restriction of access to data on beneficial owners. For more information and assistance, please contact:

  • Dubravka Lukovecki
  • Marija Perak
  • Dženet Garibović