Dear Reader,

This newsletter has been prepared by COBALT pan-Baltic Corporate practice group and covers the legal challenges in disclosure of beneficial owners in the Baltic States.

It has already been a while since the Baltic States have introduced the provisions of the Directive 2015/849 on the prevention of the use of the financial system for the purposes of money laundering or terrorist financing (the “Fourth AML Directive”) in their national laws. However, while starting from the same provisions of the Directive, the three Baltic countries have each ended up with a different set of obligations for ultimate beneficial owners (“UBOs”) of companies.

On the date of this newsletter Latvian and Estonian companies have already disclosed their beneficial owners, whereas in Lithuania the deadline for the disclosure is approaching fast. The purpose of this newsletter is to remind companies about their obligation to disclose beneficial owners in Lithuania, as well as to update on the recent developments in respect of disclosure of beneficial owners in Latvia and Estonia.

With kind regards,
COBALT Law offices


The statutory requirements of disclosure of the UBO, incorporated into the Law on Money Laundering and Terrorism Financing Prevention of the Republic in Lithuania, has entered into force from 1 January 2019. Under the provisions of the Law, obliged legal entities have an obligation to disclose their UBOs in the Informational System of Members of Legal Entities until 1 July 2019.


The deadline to disclose the beneficial owners in Latvia expired already in 1 March 2018. Nevertheless, according to public reports only less than 10% of the companies in Latvia had disclosed their beneficial owners until June 2018. Even though by now the number of such companies has increased, the results are still noticeable.


The deadline to disclose the beneficial owners in Estonia expired on 30 October 2018. Nevertheless, not all the companies have duly declared their beneficial owners.


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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