As set out in our recent Newsflash " Less than three months left for RBO filing" on our website, by the end of August 2019, all in-scope Luxembourg entities will have to be compliant with the provisions of the Luxembourg Law of 13 January 2019 creating a Register of Beneficial Owners ("RBO Law") and, in particular, file information on their beneficial owner(s) with the Register of Beneficial Owners ("RBO").

Several guidance documents have recently been made available online by the RBO:

  • Two new circulars were published. Circular LBR 19/03 concerns the treatment of foundations and  Circular LBR 19/04 covers the treatment of public undertakings and companies partially or majority owned by the State.
  • The RBO also added new user guidance, including an explanatory guide (Declaration of beneficial owners – guide) containing, in particular, schematic representations of the analysis to be performed by obliged entities when identifying their beneficial owners, as well as a brochure relating to certain formalisms of the registration process. The RBO indicates in these documents that they do not have legal value and do not constitute legal advice.

The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.