Additional Obligations to Identify Ultimate Beneficial Owners

July, 2019

Dear Reader,

We would like to inform you that the amendments to the Law on the Prevention of Money Laundering and Terrorism and Proliferation Financing (hereinafter “LPMLTPF”) are effective as of 1 July 2019 and provide, among other things, the following:

  1. Latvian branches and representation offices of foreign entities will have an obligation to disclose and register the information on their ultimate beneficial owners (hereinafter “UBOs”). These entities will need to disclose information on their UBOs until 1 January 2021, by submitting the respective information to the Commercial Register of the Register of Enterprises (RoE) or in the case of permanent establishments – with the State Revenue Service (SRS) of the Republic of Latvia. Failure to comply with these provisions until the specified deadline will result in removal of the branches and representative offices from the existing registers maintained by the RoE or SRS.
  2. Each legal person and foreign entity will have an obligation to determine and identify its UBO at its own motion if there are grounds to distrust the correctness of previously submitted information on the UBO. This obligation also includes the task to verify the correctness of information that the UBO cannot be identified.
  3. Each company that has an obligation to disclose its UBO will need to keep a set of documents substantiating the control exercised by the UBOs or evidence that the UBO cannot be identified. The RoE will have the right to request the submission of documentary evidence of the control exercised by the UBOs, or evidence that the UBO cannot be reasonably identified. Please note that some of these documents (such as personal identity documents) will need to be certified by the notary public.
  4. Each person will have the right to receive information on the UBOs of legal persons and foreign entities from the SRS and RoE.
  5. If the company has not registered its UBOs, the RoE will on its own motion make entries in the relevant registers and will identify the natural person who is a shareholder of the limited liability company, a partner of the partnership or the person holding the position of a member of the Management Board of the foundation as company’s UBO. Other companies that will fail to submit information about their UBOs or remedied the deficiency within one month of receiving a written warning from the RoE will be removed from the Commercial Register.

We will be happy to assist you in case you require support in disclosing or updating information on the UBO of your company or foreign entity. Please feel free to contact our experts:

Gatis Flinters


Marija Berdova


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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