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Changes to the regulations on the Central Register of Beneficial Ownership as of 31.10.2021

On 31.10.2021 major amendments to the AML Act concerning the Central Register of Beneficial Ownership came into force. They are particularly important as they mostly concern control measures over the reliability of processes of beneficial owners’ identification and the correctness of notifications to the CRBO.


How can we help you with this?

  • We will carry out the process of identification of beneficial owners
  • We will prepare the required XML file of CRBO-notification and help you e-sign and submit it to the CRBO
  • We will verify your current beneficial ownership findings and the CRBO entries for correctness and up-to-dateness
  • We will support preparation of an relevant internal procedure / policy aimed at securing a proper flow of
    information and, consequently, at keeping CRBO entries up-to-date
  • We will conduct workshops about the functioning of CRBO (e.g. for a selected group of employees)




If you have any questions or concerns, our team is at your disposal:

Michał Bogacz
Partner, Attorney-at-law

Paulina Szewc
Senior Associate, Attorney-at-law

Justyna Papież
Senior Associate, Attorney-at-law