Article 66 Nominee obligations

This article targets a specific transparency gap in beneficial ownership frameworks: the use of nominee arrangements.

It places direct obligations on nominee shareholders and nominee directors to identify their nominators and the beneficial owners behind them, and to disclose that information to the legal entity they nominally represent.

The legal entity is then responsible for pushing that information both to the central register and to obliged entities when customer due diligence is being carried out.

This article works in close conjunction with the broader beneficial ownership transparency requirements established across Chapter IV, essentially ensuring that nominee arrangements cannot be used to obscure the true ownership or control of a legal entity.

Important points:

• Nominee shareholders and nominee directors must maintain and disclose information on their nominator and the nominator's beneficial owners to the legal entity.
• Legal entities are required to report that nominee information to the central register.
• Legal entities must also provide this information to obliged entities when customer due diligence measures are being applied under Chapter III.