Pursuant to the Beneficial Ownership (Amendment) Act 2022 and the Beneficial Ownership (Amendment) Regulations 2023 (together the Amendments), various legislative amendments to the Beneficial Ownership Act, 2020 (the BO Act) and the Beneficial Ownership Regulations, 2020 (the BO Regulations) have come into force with effect from 30 December 2022 and 28 April 2023 respectively. The Amendments have been implemented to meet new EU and FATF Standards.
EXPANDED REGISTER OF BENEFICIAL OWNERS AND DECLARATION OF BENEFICIAL OWNERSHIP
One of the main changes brought about by the Amendments is the requirement to provide for the beneficial owner of a company as well as any nominee ( corporate or individual) the following
In view of these TIN and NIN requirements, we will require a proof of tax residency document (e.g. copy tax office notice including the TIN) and a copy of a valid national identification card or equivalent (including the NIN) for all beneficial owners and nominees specified in the Register of Beneficial Owners.
Please note that compliance with the updated BO Act and BO Regulations (as amended by the Amendments) is required by the end of this year and this involves a requirement for all Seychelles client companies/entities to re-file their Register of Beneficial Owners in the new ROBO format. However, to enable us to attend to the updating re-filings in time, we will require the copies of the documentation evidencing each beneficial owner’s/nominee’s TIN (if any) and NIN (if any) by no later than 30 September 2023.
Please note that the Register of Beneficial Owners continues to be private and will not be available to the public (only to foreign governmental agencies or law enforcement via justified legal requests to the Seychelles Government, such as in cases of suspected or proven crime).
Additionally, with respect to directors, we point out that in Seychelles there is a legal requirement to file IBC director details with the Register, but such information is not also publicly accessible.
Please contact Globalserve for further information and assistance in order to successfully complete the filing of the required information with the supportive documents.