New Disclosure Requirements Imposed on Overseas Entities Holding UK Property

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A new Register of Overseas Entities, expected this summer, requires disclosure of beneficial owners.

The UK government has introduced legislation1 in Parliament to pave the way for the launch of the new Register of Overseas Entities (the Register). The Register was one of a number of measures announced in March 2022 as part of the Economic Crime (Transparency and Enforcement) Act 2022 (ECA) in an effort to stem the flow of illicit funds through the UK in response to Russia’s invasion of Ukraine. Concerns persist that the UK provides a safe haven for money laundering, and, in particular, that large amounts of suspected ill-gotten gains are being cached in prime London real estate via foreign-registered entities whose beneficial owners are unclear. As discussed in Latham’s previous blog post, the ECA aims to address these concerns by forcing non-UK entities that hold UK property to submit information about their “registrable beneficial owners” and managing officers for inclusion on the Register.

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