Dear Reader,

Under the provisions of Article 30 of the Directive 2015/849 (Fourth AML Directive), Member States have to ensure that corporate entities obtain and hold adequate, accurate and current information on their beneficial owners. Even though the relevant provisions of the Fourth AML Directive have been adopted already in 2015, the relevant provisions of the Directive have been transposed in the national laws only recently.

The new mechanism works in parallel to the obligation to disclose and register the shareholders of corporate entities and in many countries will introduce a new set of reporting obligations for companies.

The purpose of this newsletter is to briefly describe the reporting requirements and core deadlines for the new obligations in Latvia, Lithuania and Estonia.

We will be happy to answer your specific questions or to assist in dealing with a particular corporate law issue.

With kind regards,
COBALT Law offices


The beneficial owners must provide relevant information to the companies they control until 1 February 2018. The companies must disclose the identity of their beneficial owners to the Latvian Register of Enterprises until 1 March 2018.

The information on the beneficial owners will become publicly available on 1 April 2018.


A company, non-profit association or foundation to be established after 1 September 2018 must submit the data of the beneficial owner along with the application for registration in the commercial register.

The legal entities already registered in the Estonian Commercial Register or the Register of Non-profit Associations and Foundations must disclose the identity of their beneficial owners to the Estonian Commercial Register until 30 October 2018.


The statutory requirements of disclosure of the beneficial ownership will enter into force from 1 January 2019.

Information about beneficial owners has to be provided to Registrar of the Informational System of Shareholders of Legal Persons (in Lithuanian – JADIS) until 1 July 2019.


Estonia | Tallinn
+372 6651 888

Latvia | Riga
+371 6720 1800

Lithuania | Vilnius
+370 5250 0800

Belarus | Minsk
+375 17 336 0093

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